Final Environmental Impact Report/Environmental Assessment for … · revised to munitions and...

Final Environmental Impact

Report/Environmental Assessment for the Monterey Peninsula Water

Management District Phase 1 Aquifer Storage and Recovery Project

State Clearinghouse #2004121065

Prepared for:

Monterey Peninsula Water Management District 5 Harris Court, Building G Monterey, CA 93942-0085

Contact: Henrietta Stern 831/658-5621

Prepared by:

Jones & Stokes 2600 V Street

Sacramento, CA 95818-1914 Contact: Mike Rushton

916/737-3000

August 2006

Jones & Stokes. 2006. Final Environmental Impact Report/Environmental Assessment for the Monterey Peninsula Water Management District Phase 1 Aquifer Storage and Recovery Project. State Clearinghouse #2004121065. (J&S 04637.04.) Sacramento, CA. Prepared for the Monterey Peninsula Water Management District.

Contents

Page

Chapter 1 Purpose and Format.............................................................................1-1 Introduction.............................................................................................1-1 Organization ...........................................................................................1-2

Chapter 2 Changes to the Draft EIR/EA ...............................................................2-1 Introduction.............................................................................................2-1 Acronyms................................................................................................2-1 Executive Summary................................................................................2-1

Summary of Potential Environmental Impacts and Mitigation Measures for the Proposed Project ..................................2-1 Noise.................................................................................................2-2

Chapter 3, Air Quality ...........................................................................2-12 Existing Air Quality Conditions and Ambient Air Quality Standards .......................................................................................2-12

Chapter 4, Vegetation and Wildlife .......................................................2-14 Impact Analysis...............................................................................2-14

Chapter 5, Aquatic Resources..............................................................2-15 Impact Analysis...............................................................................2-15

Chapter 8, Surface and Groundwater Hydrology and Water Quality ..................................................................................................2-17

Seaside Groundwater Basin ...........................................................2-17 Carmel River Basin.........................................................................2-19

Chapter 10, Noise.................................................................................2-22 Proposed Project ............................................................................2-22

Chapter 11, Hazards and Hazardous Materials....................................2-22 Impacts and Mitigation Measures ...................................................2-22

Chapter 17, Temporary Pipeline Analysis ............................................2-23 Impacts and Mitigation Measures ...................................................2-23

Chapter 3 Comment Letters and Responses to Comments...............................3-1 Introduction.............................................................................................3-1 Comments on the Draft EIR/EA..............................................................3-1

Comment Letter 1—California Coastal Commission, May 8, 2006 ......................................................................................3-7 Comment Letter 2—California Department of Fish and Game, May 22, 2006 ......................................................................3-17

MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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Comment Letter 3—Monterey Bay Unified Air Pollution Control District, May 4, 2006 ..........................................................3-24 Comment Letter 4—Monterey County Department of Health, May 8, 2006........................................................................3-27 Comment Letter 5—National Oceanic and Atmospheric Administration, May 4, 2006 ...........................................................3-29 Comment Letter 6— National Oceanic and Atmospheric Administration, May 22, 2006 ....................................3-32 Comment Letter 7—State Clearinghouse and Planning Unit, May 9, 2006............................................................................3-39 Comment Letter 8—California American Water, May 8, 2006................................................................................................3-44 Comment Letter 9—Carmel River Steelhead Association, May 4, 2006................................................................3-48 Comment Letter 10—Carmel Valley Association, April 17, 2006..........................................................................................3-55 Comment Letter 11—Department of Toxic Substances Control, June 1, 2006 .....................................................................3-61 Public Hearing Comment 12—Robert Greenwood, Carmel Valley Association, April 17, 2006......................................3-62 Public Hearing Comment 13—John Fischer, April 17, 2006................................................................................................3-63

Chapter 4 Revised Mitigation Monitoring Plan....................................................4-1 Vegetation and Wildlife ...........................................................................4-1 Aquatic Resources..................................................................................4-2 Cultural Resources .................................................................................4-3 Surface and Groundwater Hydrology and Water Quality........................4-5 Noise ......................................................................................................4-6 Hazards and Hazardous Materials .........................................................4-7 Public Services and Utilities....................................................................4-8 Visual Resources....................................................................................4-9 Cumulative Impacts ................................................................................4-9 Temporary Pipeline Analysis ................................................................4-11

Chapter 5 References Cited ..................................................................................5-1 Printed References.................................................................................5-1 Personal Communications......................................................................5-9

Chapter 6 Report Preparation ...............................................................................6-1 Monterey Peninsula Water Management District ...................................6-1 Jones & Stokes.......................................................................................6-1 Padre Associates, Inc. ............................................................................6-2


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Tables

Table Page

1 List of Individuals and Agencies Commenting on the Draft EIR..........................................................................................................3-2


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Acronyms and Abbreviations

AAQS ambient air quality standards AF acre-feet AFD acre-feet per day AFY acre-feet per year ASR Aquifer Storage and Recovery BMP best management practice BO Biological Opinion Cal-Am California American Water CDR Conceptual Design Report CEQA California Environmental Quality Act cfs cubic feet per second CO carbon monoxide CPUC California Public Utilities Commission CDFG California Department of Fish and Game CVSIM Carmel Valley Simulation Model CWP Coastal Water Project DEIR Draft EIR EA Environmental Assessment EIR environmental impact report GPM gallons per minute

HTRW Hazardous, Toxic and Radioactive Waste

MBUAPCD Monterey Bay Unified Air Pollution Control District MEC Munitions and Explosives of Concern mgd million gallons per day MMP Mitigation Monitoring Plan MOA Memorandum of Agreement MPWMD or the District Monterey Peninsula Water Management District MPWRS Monterey Peninsula Water Resources System MR RI/FS Munitions Response Remedial

Investigation/Feasibility Study NAHC Native American Heritage Commission NEPA National Environmental Policy Act


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NOAA Fisheries or NMFS National Marine Fisheries Service NCCAB North Central Coast Air Basin NOx oxides of nitrogen NPDES National Pollutant Discharge Elimination System NRMA Natural Resources Management Area PEA Proponent’s Environmental Assessment PM10 particulate matter less than or equal to 10 microns in

diameter Proposed Project Construction and operation of an aquifer storage and

recovery project REL reference exposure level

RM River Mile

ROG reactive organic gases RWQCB Regional Water Quality Control Board SAA Streambed Alteration Agreement SGB Seaside Groundwater Basin SMTIW Santa Margarita Test Injection Well SWRCB State Water Resources Control Board USACE U.S. Army Corps of Engineers USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey UXO Unexploded ordnance


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Chapter 1 Purpose and Format

Introduction Under the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA), the lead agency for a proposed project is required to consult with and obtain comments from public agencies with legal jurisdiction concerning the proposed project and to provide the general public with opportunities to comment on the draft EIR/EA after completion of a draft environmental impact report (EIR)/environmental assessment (EA). The lead agency is also required to respond to significant environmental points raised during the review and consultation process.

This final EIR/EA addresses the Monterey Peninsula Water Management District’s (MPWMD; also referred to as the District) proposal to construct and operate an aquifer storage and recovery (ASR) project that would allow diversion of a limited amount of flow from the Carmel River during high flow conditions for storage in, and later recovery from, the Seaside Groundwater Basin. The ASR project would divert up to 2,426 acre-feet (AF) per year from the Carmel River between December and May. This document also addresses the construction, operation, and removal effects of a temporary aboveground water supply pipeline being proposed by California American Water (Cal-Am) in the vicinity of the proposed new ASR well. The final EIR/EA contains the public and agency comments received during the state and federal agency and public review period on the draft EIR/EA, which was held from March 23 to May 8, 2006, with an extension to May 22, 2006. The MPWMD also held a public comment meeting on April 17, 2006. Responses to comments raised during this meeting are addressed in Chapter 3, “Comment Letters and Responses to Comments,” of this document.

Copies of the draft EIR/EA and additional copies of this final EIR/EA are available for review at the Monterey Peninsula Water Management District, 5 Harris Court, Building G, Monterey, CA 93940. The draft EIR/EA is incorporated by reference into this final EIR/EA and will not be reprinted.


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Monterey Peninsula Water Management District Purpose and Format

Organization This final EIR/EA is organized as follows:

Chapter 1, “Purpose and Format,” describes the purpose and organization of this final EIR/EA.

Chapter 2, “Changes to the Draft EIR/EA,” includes changes to the draft EIR/EA initiated by the lead agencies (MPWMD and U.S. Army) and changes to the draft EIR/EA that are identified in responses to comments. Changes to the draft EIR/EA are identified by either a line through the text showing deleted text or underlining where new text has been inserted.

Chapter 3, “Comment Letters and Responses,” contains the comment letters on the draft EIR/EA followed by responses to the comments. Each letter and each comment within a letter has been assigned a number. Responses are numbered to correspond to the appropriate comment.

Chapter 4, “Revised Mitigation Monitoring Plan,” includes the changes to the draft Mitigation Monitoring Plan (MMP). Changes to the draft MMP are identified by either a line through the text showing deleted text or double underlining where new text has been inserted.

Chapter 5, “References Cited,” lists the printed documents and individuals consulted during preparation of this final EIR/EA.

Chapter 6, “Report Preparation,” contains a list of the individuals that assisted in the preparation of this final EIR/EA.


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Chapter 2 Changes to the Draft EIR/EA

Introduction This chapter presents changes to the draft EIR/EA that were either initiated by the MPWMD or the U.S. Army or that are explained in the responses to comments in Chapter 3. The changes are presented below in the order in which they appeared in the draft EIR/EA. When relevant, explanatory text is provided in italics.

Deletions are shown in strikeout text. Additions are underlined.

Acronyms The following corrections are made to page xix of the draft EIR/EA in response to a comment from the Department of Toxic Substances Control. In addition, all subsequent occurrences of the phrase unexploded ordnance (or UXO) are hereby revised to munitions and explosives of concern (or MEC).

UXO Unexploded ordnance MEC Munitions and explosives of concern

Executive Summary

Summary of Potential Environmental Impacts and Mitigation Measures for the Proposed Project

The following corrections are made to page ES-5 of the draft EIR/EA in response to a comment from the MBUAPCD.


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Monterey Peninsula Water Management District Changes to the Draft EIR/EA

Air Quality

Constructing the injection/extraction well and pipeline would result in short-term increases in PM10 and exposure of sensitive receptors to diesel particulate matter and acrolein. The impact on air quality resulting from the short-term increases in PM10 emissions was considered less-than-significant. The short-term impact of diesel particulate matter and acrolein emissions was also considered less than significant significant. The preferred project well site is sufficiently removed from sensitive receptors and the construction period is sufficiently short to avoid a significant increase in health risk. because of the close proximity of sensitive receptors to the construction site. These impacts would be mitigated to a less-than-significant level by implementing emission-reducing construction practices.

The following corrections are made to page ES-8 of the draft EIR/EA in response to a comment from the MBUAPCD.

Noise Constructing the injection/extraction well and pipeline would expose adjacent sensitive land uses to noise and vibration in excess of applicable standards. These potentially significant impacts would occur as a result of using heavy equipment at the construction site and the necessity to drill at 24-hours-per-day until the well is completed. Noise and vibration impacts could be reduced to a less than significant level by limiting the use of unnecessary equipment ancillary to the drilling rig to daylight hours and employing noise-reducing construction practices. Operating the injection/extraction well could result in a significant impact on adjacent noise-sensitive land uses. This impact would be reduced to a less than significant level by designing an enclosure that adequately attenuates noise to meet local standards.

The following corrections are made to Table ES-1 of the draft EIR/EA in response to comments from the MBUAPCD, National Oceanic and Atmospheric Administration National Marine Fisheries Service (NOAA Fisheries; formerly referred to as NMFS), and the Department of Toxic Substances Control.


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Table ES-1. Summary of Impacts and Mitigation Measures for the Proposed Project

Issue Area Potential Impact Significance Determination without Mitigation Mitigation

Significance Determination with Mitigation

Air Quality AQ-1: Short-Term Increase in PM10 Emissions from Well Drilling

Less than Significant None required Less than Significant

AQ-2: Short-Term Increase in PM10 Emissions from Pipeline Construction


AQ-3: Short-Term Increase in PM10 Emissions from Building Construction


AQ-4: Exposure of Sensitive Receptors to Elevated Health Risks from Exposure to Diesel Particulate Matter from Construction Activities

Less than Significant Mitigation Measure AQ-1. Use Newer, Cleaner-Burning Engines.

Mitigation Measure AQ-2. Limit Construction Duration.

Less than Significant

AQ-5: Exposure of Sensitive Receptors to Elevated Health Risks from Exposure to Acrolein Emissions from Diesel Exhaust from Construction Activities

Less than Significant Significant

Mitigation Measure AQ-1. Use Newer, Cleaner-Burning Engines.

Mitigation Measure AQ-2. Limit Construction Duration.

Less than Significant

Vegetation and Wildlife

BIO-1: Removal of Maritime Chaparral Less than significant None required Less than significant

BIO-2: Disturbance of the Fort Ord NRMA Significant Mitigation Measure BIO-1: Minimize or Prevent Disturbance to Adjacent NRMA

Less than significant

BIO-3: Destruction of Monterey Spineflower, Sandmat Manzanita, Eastwood’s Goldenbush, and Kellogg’s Horkelia

Less than significant None required Less than significant

BIO-4: Potential Direct Mortality or Disturbance of California Horned Lizards and Potential Permanent and Temporary Loss of California Horned Lizard Habitat



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BIO-5: Potential Direct Mortality or Disturbance of Black Legless Lizards and Potential Permanent and Temporary Loss of Black Legless Lizard Habitat

Significant None required; mitigation is included in the Fort Ord Multispecies Habitat Management Plan


BIO-6: Potential Direct Mortality or Disturbance of Monterey Dusky-Footed Woodrat and Potential Permanent and Temporary Loss of Monterey Dusky-Footed Woodrat Habitat

Significant None required; mitigation is included in the Fort Ord Multispecies Habitat Management Plan


BIO-7: Potential Direct Mortality or Disturbance of American Badger and Potential Permanent and Temporary Loss of American Badger Habitat


BIO-8: Potential Loss of Nest Trees and Disturbance or Mortality of Migratory Birds

Less than significant Mitigation Measure BIO-4: Remove Trees and Shrubs during the Nonbreeding Season for Most Birds (September 1 To February 15).


Aquatic Resources

AR-1: Improved Flows for Upstream Migration Change in Flows for Adult Steelhead Upstream Migration

Beneficial Mitigation Measure AR-1: Conduct Annual Survey Below River Mile 5.5 and Monitor River Flow in January-June Period.

None required

Beneficial

AR-2: Change in Juvenile Steelhead Rearing Habitat

Beneficial Mitigation Measure AR 5-2: Cooperate to help develop a Project to Maintain, Recover, or Increase Storage in Los Padres Reservoir and If Needed, Continue Funding Program to Rescue and Rear Isolated Juveniles

Beneficial

AR-3: Improved Flows for Fall/Winter Downstream Migration

Beneficial None required Beneficial


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AR-4: Maintenance of Flows for Spring Emigration


AR-5: Changes in California Red-legged Frog Habitat Due to Changes in River Flows

Beneficial

None required Beneficial

AR-6: Changes in Habitat for Other Aquatic Species Due to Changes in River Flows


Cultural Resources

CR-1: Potential for Discovery of Buried Cultural Deposits and Human Remains during Construction of the Well and Pipelines

Significant Mitigation Measure CR-1: Stop Work If Buried Cultural Deposits Are Encountered during Construction Activities.

Mitigation Measure CR-2: Stop Work If Human Remains Are Encountered during Construction Activities.


Geology, Soils, and Seismicity

GS-1: Potential Short-Term Increase in Erosion Resulting from Project Construction


GS-2: Potential Structural Damage and Threat to Public Safety from Fault Displacement and Ground Shaking during a Seismic Event


GS-3: Potential Structural Damage and Threat to Public Safety from Earthquake-Induced Liquefaction and Lateral Spread


GS-4: Potential Rupture of Pipelines and Threat to Public Safety Caused by Expansive Soils and Pipeline Corrosion


Surface and Groundwater Hydrology and Water Quality

GWH-1: Changes in Seaside Basin Groundwater Storage


GWH-2: Short-Term Changes in Seaside Basin Groundwater Quantity



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GWH-3: Long-Term Changes in Seaside Basin Groundwater Levels


GWH-4: Changes in Seaside Basin Groundwater Levels in Overlying Units


GWH-5: Potential for Seaside Basin Hydrofracturing


GWH-6: Short-Term Change in Seaside Basin Groundwater Quality

Less than significant Mitigation Measure GWH-1: Comply with Performance Standards in NPDES Permits


GWH-7: Long-Term Change in Seaside Basin Groundwater Quality From Mixing Groundwater with Injected Water

Less than significant Mitigation Measure GWH-2: Operate Project in Compliance with SWRCB and DHS Policies

Mitigation Measure GWH-3: Modify Project Operations as Required by Results of Monitoring


GWH-8: Changes in Seaside Basin Groundwater Quality Caused by ASR Well Operation Discharges


GWH-9: Changes in Seaside Basin Recovered Water Quality


GWH-10: Effects on Other Seaside Basin Groundwater Users


GWH-11: Changes in Carmel River Streamflow During High Flow Periods

Less than significant Mitigation Measure GWH-4: Operate Project in Compliance with NOAA Fisheries Recommendations, and Reduce Unlawful Diversions


GWH-12: Changes in Carmel Valley Alluvial Aquifer Storage During High Flow Periods



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GWH-13: Changes in Carmel River Streamflow During Low Flow Periods

Less than significant Mitigation Measure GWH-4: Operate Project in Compliance with NOAA Fisheries Recommendations, and Reduce Unlawful Diversions


GWH-14: Changes in Carmel Valley Alluvial Aquifer Storage During Low Flow Periods

Beneficial

None required Beneficial

Land Use LU-1: Disruption of Existing Land Uses or Neighborhoods during Construction of the Well Site


LU-2: Disruption of Existing Land Uses or Neighborhoods during Construction of the Santa Margarita Well Pipeline and New Well Pipeline


LU-3: Incompatibility with Existing Adjacent Land Uses from Operation of the Proposed Pipelines and Well


LU-4: Potential Inconsistencies with Relevant Land Use Plans and Policies from Operation of the Proposed Well and Pipelines



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Noise NZ-1: Exposure of Noise-Sensitive Land Uses to Construction Noise in Excess of Applicable Standards

Significant Mitigation Measure NZ-1a: Prohibit Ancillary and Unnecessary Equipment During Nighttime Well Drilling Activities.

Mitigation Measure NZ-1b: Employ Noise-Reducing Construction Practices to Meet Nighttime Standards.

Mitigation Measure NZ-1c: Prepare a Noise Control Plan.

Mitigation Measure NZ-1d: Disseminate Essential Information to Residences and Implement a Complaint/Response Tracking Program.


NZ-2: Exposure of Sensitive Land Uses to Construction-Related Vibration Levels in Excess of Applicable Standards

Significant Mitigation Measure NZ-1a

Mitigation Measure NZ-1b

Mitigation Measure NZ-1c

Mitigation Measure NZ-1d


NZ-3: Exposure of Sensitive Land Uses to Operational Noise in Excess of City Standards

Significant Mitigation Measure NZ-2: Design Pump Stations to Meet Local Noise Standards.


Hazardous Materials

HAZ-1: Exposure of Employees and Public to Hazardous Materials during Construction of a Well and Pipelines at the Former Fort Ord

Significant Mitigation Measure HAZ-1: Implement MEC UXO Safety Precautions during Grading and Construction Activities at the Project Site.


HAZ-2: Handling and Use of Hazardous Materials during construction within 0.25 Mile of a School



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HAZ-3: Potential Creation of a Hazard to the Public and Environment from Routine Use of Hazardous Materials or Accidental Release of Hazardous Materials during Operation of the Well Site


HAZ-4: Handling of Hazardous Materials during operation within 0.25 Mile of a School


HAZ-5: Public Exposure to Contaminated Drinking Water


Public Services and Utilities

PS-1: Increase in Solid Waste Generation and Construction Debris during Construction of Well and Pipelines

Less than significant None required


PS-2: Temporary Disruption of Existing Underground Utilities and Utility Service during Construction of Well and Pipelines

Significant Mitigation Measure PS-2: Coordinate Relocation and Interruptions of Service with Utility Providers during Construction

Mitigation Measure PS-3: Protect All Existing UtilitiesSlated to Remain


PS-3: Increased Demand for Electricity from Operation of ASR Facilities


Transportation and Circulation

TR-1: Temporary Traffic Increase and Potential for Level of Service Degradation during Construction of Wells and Pipelines


TR-2: Potential Conflict with Fixed-Route Monterey-Salinas Transit Service during Construction of Wells and Pipelines


TR-3: Potential Pedestrian and Bicycle Hazards from Pathway and Bikeway Closures or Disruption during Construction of Well and Pipelines



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TR-4: Potential for Increased Traffic and Level of Service Degradation from Operation and Maintenance of the Well Site


TR-5: Increased Parking Demand Attributable to Operations and Maintenance of the Well


Visual Resources

VIS-1: Temporary Alteration of Scenic Views during Construction of Well and Pipelines


VIS-2: Degrade Existing Visual Character during Construction of Well and Pipelines


VIS-3: Creation of Light and Glare during Construction of Well and Pipelines


VIS-4: Alteration of Existing Visual Character at Well Site


VIS-5: Creation of New Light and Glare at Well Site

Significant Mitigation Measure VIS-3: Incorporate Light-Reduction Measures into the Plan and Design of Exterior Lighting at Well Site.


Cumulative Impacts

The Proposed Project could result in cumulative impacts on traffic and transportation


The Proposed Project could result in a considerable contribution to NOx and PM10 emissions when considered together with other projects that could be constructed in the same timeframe.

Significant Mitigation Measure Cume-1: Coordinate with Relevant Local Agencies to Develop and Implement a Phased Construction Plan to Reduce Cumulative Traffic, Air Quality, and Noise Impacts



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The Proposed Project could contribute considerably to construction noise and vibration, affecting sensitive receptors when considered together with other projects that could be constructed in the same timeframe in the same area and affecting the same sensitive noise receptors.

Significant Mitigation Measure Cume-1 Less than significant

Construction of the well and associated pipelines could result in the loss or disturbance to special-status plant and wildlife species or their habitat.


There would be a cumulative energy effect from the Proposed Project because operation of the new ASR well would require 10,000 killowat hours of electricity daily.



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Chapter 3, Air Quality Existing Air Quality Conditions and Ambient Air Quality Standards

The following corrections are made to page 3-5 of the draft EIR/EA in response to a comment from the Monterey Bay Unified Air Pollution Control District (MBUAPCD).

The State of California has designated the NCCAB as being in moderate nonattainment transitional for ozone. The California Clean Air Act states that an ozone nonattainment area becomes nonattainment transitional if the state AAQS are not exceeded more than three times at any monitoring station in the air basin. The NCCAB is designated nonattainment for PM10 and unclassified/attainment for CO.

The following corrections are made to page 3-6 of the draft EIR/EA in response to a comment from the MBUAPCD.

The existing air quality conditions in the project study area can be characterized by monitoring data collected in the region. PM10, CO, and ozone concentrations are the pollutants of greatest concentration in the MBUAPCD and, therefore, are the pollutants of most concern from the Proposed Project. Air quality monitoring data for the last 3 years are presented in Table 3-2. The closest monitoring stations in the vicinity of the Proposed Project areis:

Monterey Silver Cloud Court (ozone)

Salinas High School (ozone, CO, and PM10)

Moss Landing—Sandholt School (PM10)

Salinas (ozone, CO, and PM10)

The following corrections are made to page 3-11 of the draft EIR/EA in response to a comment from the MBUAPCD.

The State CEQA Guidelines further state that the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the determinations above. The MBUAPCD has specified significance thresholds within its CEQA Air Quality Guidelines (2002July 2004) to determine whether project-related air quality impacts need mitigation. Based on consultation with MBUAPCD staff (Brennan pers. comm.) and the MBUAPCD’s CEQA air quality guidelines, Table 3-5 summarizes applicable thresholds that are used in the analysis of significant air quality impacts.

The following corrections are made to pages 3-14 and 3-15 of the draft EIR/EA in response to a comment from the MBUAPCD, and subsequent email and


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telephone conversations with air pollution control district staff. The mitigation measures have been removed because they are only necessary to support construction at the alternative well site (adjacent to the Roger S. Fisk Middle School). These measures are not necessary to protect public health if the Proposed Project is approved by the MPWMD Board of Directors. The proposed well site is sufficiently removed from the school grounds to avoid adverse effects.

Emissions of diesel particulate matter have the potential to result in elevated health risks. The assessment of cancer risk is typically based on a 70-year exposure period. Construction activities are sporadic, transitory, and short-term in nature, and once construction activities cease, so too will emissions from construction. Conversation with MBUAPCD staff indicates that construction activities that occur for less than 1 year will generally not result in any adverse health impacts. As indicated in Table 3-4, construction activities are anticipated to occur for a period of 2 months. Because construction activities are less than 1 year in duration, this impact is considered less than significant. However, to further reduce emissions of DPM and associated health risks, Mitigation Measures AQ-1 and/or AQ-2 are recommended.

Mitigation Measure AQ-1: Implement Emissions Control TechnologyUse Newer, Cleaner-Burning Engines. The project applicant will provide a plan, for approval by the lead agency and AQMD, demonstrating that the heavy-duty (> 50 horsepower) off-road vehicles to be used in the construction project, including owned, leased and subcontractor vehicles, will achieve a project wide fleet-average 20 percent NOX reduction and 45 percent particulate reduction compared to the most recent CARB fleet average at time of construction. Control measures available to achieve emissions reductions include, but are not limited to:encourage all construction contractors that use equipment with diesel engines to use as much equipment as possible that meets EPA Tier II engine standards. The project applicant will also encourage construction contractors to install use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology (e.g., diesel particulate matter filters and lean-NOx or diesel oxidation catalysts) after-treatment products, and/or other options as they become available. in all equipment, especially equipment that doesn’t meet Tier II engine standards.

Mitigation Measure AQ-2: Limit Construction Duration. To minimize potential exposure of students at the nearby Roger S. Fitch Middle School (Figure 2-3) to TACs associated with diesel exhaust from construction activities, construction activities should occur as much as possible when prevailing winds are away from the school, based on on-site meteorological monitoring data, and when students are away from the school site. The project applicant shall consult with the Monterey County Office of Education to establish a schedule indicating when school will be out of session and when students will not be present on school grounds. This schedule will be used to help determine when construction activities in the vicinity of the school may occur.


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Impact AQ-5: Exposure of Sensitive Receptors to Elevated Health Risks from Exposure to Acrolein Emissions from Diesel Exhaust from Construction Activities

Construction equipment and the test well pump may be diesel and could therefore emit diesel exhaust. Acrolein is emitted as a product of diesel combustion, where the concentration in diesel exhaust is currently understood to be 0.0035 grams acrolein per gram of ROG emissions. An acute one-hour reference exposure level (REL) of 0.19 µg/m3 has been determined. Since construction would occur at a substantial distance from the nearest sensitive receptor, acrolein emissions would not cause acute health risks. Consequently, this impact is considered to be less than significant. Using methods developed by the MBUAPCD, a screening analysis conducted for project construction indicates that the hazard index for acrolein exposure may exceed 1 at nearby sensitive receptors at the two potential locations for the well sites. Consequently, this impact is considered significant. Implementation of Mitigation Measures AQ-1 and/or AQ-2 would reduce these impacts to a less-than-significant level.

Mitigation Measure AQ-1: Use Newer, Cleaner-Burning Engines.

Mitigation Measure AQ-2: Limit Construction Duration.

Mitigation: No mitigation is required.

Chapter 4, Vegetation and Wildlife Impact Analysis

Impacts and Mitigation Measures

The following corrections are made to page 4-18 of the draft EIR/EA by the MPWMD to clarify the entity that serves as the local fire district for the property at the ASR Project location.

Mitigation Measure BIO-1: Minimize or Prevent Disturbance to Adjacent NRMA To prevent disturbance of the adjacent NRMA, management measures will be carried out during project construction and operation to minimize construction effects and the potential for introducing invasive nonnative species. The construction contractor will implement BMPs to prevent the spread outside the construction area of construction materials, oil and fuel, sidecast soil, dust, or water runoff. All invasive nonnative plants, such as iceplant or pampas grass, will be removed from the construction area prior to site disturbance to avoid the spread of plant fragments or seeds. A firebreak consistent with the requirements of the local fire district Presidio of Monterey Fire Department and acceptable to


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the City of Seaside Fire Department will be located and maintained by MPWMD between the well site and the adjacent NRMA.

The following corrections are made to page 4-21 of the draft EIR/EA in response to a comment from the California Department of Fish and Game (CDFG). The numbering of Mitigation Measure BIO-4 has also been changed to Mitigation Measure BIO-2 due to a typographical error.

Mitigation Measure BIO-42: Remove Trees and Shrubs during the Nonbreeding Season for Most Birds (September 1 To February 15) Clearing of the site for construction of the well and associated facilities and the pipeline, and subsequent inspection, maintenance and cleaning activities will result in the removal of trees and shrubs that provide suitable nesting habitat for migratory birds. To avoid the loss of active migratory bird nests, tree and shrub removal will be conducted only during the nonbreeding season for migratory birds (generally September 1 to February 15). Removing woody vegetation during the nonbreeding season will ensure that active nests will not be destroyed by removal of trees supporting or adjacent to active nests.

Chapter 5, Aquatic Resources Impact Analysis


On page 5-21 of the draft EIR/EA, Impact AR-1 has been revised and Mitigation Measure AR-1 has been added in response to verbal and written comments from NOAA Fisheries.

Impact AR-1: Reduced Flows for Adult Upstream Migration Improved Flows for Upstream Mitigation

Compared to existing No Project conditions, operation of the ASR Project would improve opportunities for upstream migration by slightly increasing the duration of attraction flows and lengthening the duration of the migration season. On average, the Proposed ASR Project would provide 38 days of attraction flows (the minimum flows, ranging from 75 cfs to 200 cfs depending on year type, that induce steelhead to enter the river from the ocean) and would provide at least two weeks (14 days) of attraction flows during the average dry, below-normal, and above-normal, and wet years; and no difference in critically-dry years (Figures 5-6 and 5-7). Although the average number of attraction days and the duration is increased by only one day, I In dry years the attraction days are increased by two days (Figure 5-6) and the duration of the migration season increases by three days (Figure 5-7). Although small, these differences are considered a significant beneficial impact because steelhead migrate over a short time period of three to six-weeks long period in dry years, so increases of a few days in years with naturally overwhelming constraints will increase the probability that a larger


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portion of the potential run will successfully migrate and spawn in the upper river. For this reason, the overall impact on upstream migration is considered a small, but beneficial impact. Although mitigation is not required, the following mitigation would ensure that the lower Carmel River is adequately monitored.

Mitigation Measure AR-1: Conduct Annual Survey below River Mile 5.5 and Monitor River Flow in January–June Period. Even though the project impact is beneficial and no mitigation is required, the following mitigation is proposed to ensure adequate monitoring of the lower Carmel River. At the beginning of each diversion season and following each storm with a peak flow greater than 3,000 cfs, the District shall conduct a survey of the river channel below RM 5.5 and identify five specific locations where low flows or the channel configuration could potentially block or impair upstream migration of adult steelhead.1 During the period from December 1 through May 31 when water is being diverted from the Carmel River and injected into the Seaside Groundwater Basin, the District shall monitor flow at the Highway One Bridge, and water currents, depths, and channel configuration at each of the five sites previously identified. If evidence of impairment or blockage is found, the District shall cease diverting until flow increases or until the channel configuration is modified so as to alleviate the blockage or impairment. In the event that channel conditions improve or deteriorate for more than two seasons, the bypass flow criteria shall be reexamined and may be modified by agreement between NOAA Fisheries, California Department of Fish and Game, and the Monterey Peninsula Water Management District.

On page 5-23 of the draft EIR/EA, Mitigation Measure AR-2 has been revised by the MPWMD to better clarify the role of the MPWMD and Cal-Am in the operation of Los Padres Dam and Reservoir.

Mitigation Measure AR-2: Cooperate to Help Develop a Project to Maintain, Recover, or Increase Storage in Los Padres Reservoir and If Needed, Continue Funding Program to Rescue and Rear Isolated Juveniles To ensure the continued benefit of the Proposed Project to the Carmel River and dependent resources during future low-flow periods, MPWMD will encourage and work with Cal-Am, CDFG, and NMFS NOAA Fisheries to investigate and develop a project to improve summer flows and the quality of releases by maintaining, recovering, or increasing surface storage capacity in the existing Los Padres Reservoir. MPWMD will provide staff expertise and data, as requested but does not control the reservoir. Cal-Am, as owner and operator of Los Padres Dam and Reservoir, is responsible for maintenance of the dam and compliance with existing regulations including water right conditions. The MPWMD will request that Cal-Am develop an updated elevation-capacity curve

1 Potential impairment or blockage shall be monitored by measuring water depths at the shallowest points at 2-foot intervals along the crest of riffles. For the purpose of monitoring and assessing the need for channel modifications, the potential for impairment and/or blockage shall be based on the following criteria: blockage, if the width and depth of a continuous section is less than 5 feet wide and > 0.6 feet deep; impaired, if the width and depth of a continuous section is five to ten feet wide and > 0.6 feet deep, and no impairment, if the width and depth of a continuous section is ≥ 10 feet wide and > 0.6 feet deep. MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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for Los Padres Reservoir that provides current estimates of the amount of storage capacity available at various elevations in the reservoir area.

In the meantime, MPWMD will continue operation and funding of its the program to rescue and rear juveniles steelhead that are stranded isolated downstream of the USGS Robles del Rio gaging station at Robles del Rio (RM 14.4). This program is part of the District's mitigation program that was adopted in 1990 when the MPWMD Board certified the MPWMD Water Allocation Program EIR. Without significant progress in maintaining recovering storage capacity in Los Padres Reservoir, and obtaining an alternate source of water, this the rescue program will be needed in most years, especially as Los Padres Reservoir continues to fill with sediment and the ability to maintain flow releases continues to diminish.

Chapter 8, Surface and Groundwater Hydrology and Water Quality

Seaside Groundwater Basin


Impact GWH-1: Changes in Seaside Basin Groundwater Storage

The following paragraphs have been added to page 8-11 of the draft EIR/EA in order to clarify the impact discussion.

As indicated earlier, increased groundwater storage in the coastal area of the SGB would result in increased outflow to the offshore portions of the aquifers in the basin. For the 45-year period of analysis, simulated subsurface outflow from the coastal area with No Project would average 410 AF per year and range from 32 AF in Water Year 1991 to 830 AF in Water Year 1958. The median or typical subsurface outflow with No Project would be approximately 420 AF per year. With the Proposed Project and elevated water levels due to increased storage, simulated subsurface outflow would average 910 AF per year and range from 90 AF in Water Year 1991 to 1,960 AF in Water Year 1984. The median or typical subsurface outflow with the Proposed Project would be approximately 850 AF per year.

As indicated in the Project Operations section later in this chapter, a revised version of CVSIM3 (Version 6.4) was developed to address concerns expressed by commenters on the Draft EIR/EA. For the Final EIR/EA, two revisions were incorporated into the operations model. First, the logic was revised to require that the water diverted from the Carmel River by Cal-Am during the high-flow season for injection would be supplied by wells in the reach between San Clemente Dam and RM 5.5. This revision was made to ensure that the


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operations were consistent with Condition 5 of SWRCB Order 95-10 that requires Cal-Am to satisfy the water demands of its customers by extracting water from its downstream wells to the maximum extent feasible. By moving the diversion point for water for injection from the reach below RM 5.5 to the reach above RM 5.5, less water would be available for injection because the bypass flow requirements in the reach above RM 5.5 are greater than the requirements in the reach below RM 5.5. Second, the logic was revised to include more explicit rules governing how and when the injected water in the Seaside Basin would be recovered. These “recovery” rules would be similar to the bypass flow requirements recommended by NMFS that govern how and when water can be diverted from the Carmel River for injection. The recovery rules were developed in cooperation with staff from CDFG and NMFS and were designed to provide assurance that the excess water diverted from the Carmel River by Cal-Am and injected into the Seaside Basin during the high-flow period would be used by Cal-Am to meet customer demand during the low-flow period rather than pumping from Carmel River sources. The recovery rules were developed to provide an explicit accounting procedure to track the water injected, stored, and recovered over time. The revised simulation results for the Phase 1 ASR Project were compared with the original simulation results and did not differ significantly.

Because of the revisions described above, the injected water would be recovered and used sooner than in the original simulations. By using the injected water sooner, less water would remain in storage in the Seaside Basin and less water would move offshore as subsurface outflow. Specifically, during wet years, simulated end-of-month usable storage in the coastal area of the SGB would be between 1,230 and 2,490 AF greater with the Proposed Project. During normal years, the increases in usable storage with the Proposed Project would range from 1,200 to 1,820 AF. During dry years, simulated storage would be between 970 and 1,570 AF greater with the Proposed Project. During critically dry years, simulated usable storage would be between 400 and 1,400 AF greater with the Proposed Project. As indicated in the Draft EIR/EA, the Proposed Project would have a beneficial effect on SGB storage

Based on the reduction in storage in the Seaside Basin with the revised logic, especially during normal and wet years, the simulated subsurface outflow offshore with the Proposed Project would be reduced. These “losses” would average 660 AFY and range from 110 AF in Water Year 1991 to 1,150 AF in Water Year 1984. The median or typical subsurface outflow with the Proposed Project would be approximately 700 AFY.


The following changes have been added to page 8-20 of the draft EIR/EA in order to consistently identify the phrase Proposed Project with capital letters.


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Mitigation Measure GWH-2: Operate Project in Compliance with SWRCB and DHS Policies MPWMD shall operate the pProposed pProject in compliance with the SWRCB's Anti-Degradation Policy (Resolution 68-16), and applicable DHS regulations regarding drinking water quality.

Carmel River Basin

Project Operations

The following paragraphs have been added to page 8-22 of the draft EIR/EA in order to clarify the text.

Other changes to CVSIM3 included a 139-acre increase in the amount of riparian areas and a 5-acre decrease in non-wooded areas between San Clemente Dam and the Carmel River Lagoon. The net affect of these changes in riparian and non-wooded areas was a 500 acre-foot increase in annual water use by riparian vegetation between San Clemente Dam and the Carmel River Lagoon, compared to previous simulations. This change in riparian area and associated evapotranspiration was calculated by District staff (Christensen 2003) based on 2001 orthoimagery from San Clemente Dam to the Carmel River Lagoon. Previous estimates of riparian area along the Carmel River were based on 1986 aerial photographs.

As discussed above in Impact GWH-1, a revised version of CVSIM3 (Version 6.4) was developed to address concerns expressed by commenters on the Draft EIR/EA. For the Final EIR/EA, two revisions were incorporated into the operations model. First, the logic was revised to require that the water diverted from the Carmel River by Cal-Am during the high-flow season for injection would be supplied by wells in the reach between San Clemente Dam and RM 5.5. By moving the diversion point for water for injection from the reach below RM 5.5 to the reach above RM 5.5, less water would be available for injection because the bypass flow requirements in the reach above RM 5.5 are greater that the requirements in the reach below RM 5.5. Second, the logic was revised to include more explicit rules governing how and when the injected water in the Seaside Basin would be recovered. The recovery rules were developed to provide assurance that the excess water diverted from the Carmel River by Cal-Am and injected into the Seaside Basin during the high-flow period would be used by Cal-Am to meet customer demand during the low-flow period rather than pumping from Carmel River sources. With the proposed recovery rules, the amount of water that can be recovered each year is tied to the amount of water that was injected during the current year (i.e., during the preceding injection season, and if necessary, injected water in storage from previous years).

The revised logic for the recovery operations was designed to provide an explicit accounting procedure to track the amount of water injected, stored, and recovered each year. The logic in the original simulation of the Proposed Project used an implicit method to quantify the increased yield from the Seaside Basin due to the


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Proposed Project. This yield was calculated as the difference between the Cal-Am’s total production from the coastal area of the Seaside Basin with and without the Proposed Project. For the Final EIR/EA, the logic for the Proposed Project was revised to use a more explicit method. In the revised simulation, the amount of water diverted for injection, the amount of water injected, the amount of water recovered, and the amount of injected water in storage in the Seaside Basin were tracked on a daily basis. In this regard, Cal-Am’s production of non-ASR water (i.e., naturally occurring water) from the Seaside Basin was tracked separately from Cal-Am’s production of ASR water (i.e., injected water) from the Seaside Basin. The recovery rules used in the revised simulation for the Proposed Project were specified so that the results (e.g., streamflow, groundwater storage, production, and months of rationing) from the original and revised simulation runs were the same or similar.

Operating Logic

The following corrections are made to page 8-23 of the draft EIR/EA in response to a comment from the Carmel River Steelhead Association.

This operating logic was chosen to facilitate comparisons between the No Project and Proposed Project simulation results. Actual operations may differ depending on future project objectives. In response to future hydrologic conditions, actual operations may vary in certain periods as determined by the interagency management group (i.e., MPWMD, Cal-Am, CDFG, and NMFS). For example, more water could be extracted from the SGB in April and May and less in October and November to provide increased flows for steelhead smolt emigration in the spring and less flow for juvenile rearing in the fall. Similarly, more storage in the SGB could be held in reserve for municipal use during extended dry periods. The magnitude and range of Cal-Am’s production from the coastal area of the SGB due to operation of the proposed Proposed Project is explained further in the “Project Yield” section.

Project Yield

The following paragraphs have been added to page 8-26 of the draft EIR/EA in order to clarify the text.

Lastly, it should be noted that the incremental firm yield associated with the Proposed Project is part of Cal-Am’s overall yield from the MPWRS. For both simulations, i.e., No-Project and Proposed Project, overall annual production from the MPWRS to serve Cal-Am’s main system was set at a maximum of 15,285 AF. Therefore, any increase in Cal-Am’s ability to reliably divert from the coastal area of the SGB due to the Proposed Project would result in a corresponding decrease in Cal-Am’s need to continue to divert from the Carmel River alluvial aquifer. None of the increased yield from the SGB due to the Proposed Project will be provided to new connections or intensified existing uses.


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As discussed above, a revised version of CVSIM3 (Version 6.4) was developed to address concerns expressed by commenters on the Draft EIR/EA. These revisions resulted in less water being available for diversion for injection and, as a consequence, less yield for the Proposed Project. Based on the revised simulation, the increased average yield from the coastal area of the Seaside Basin due to the Proposed Project would be 916 AFY. Annual injections during this period would average 918 AFY. During the six-month recovery season, approximately 100 to 120 AF per month would be recovered from the Seaside Basin and not diverted from the Carmel River by Cal-Am.


Impact GWH-11: Changes in Carmel River Streamflow During High Flow Periods

The following text is added to page 8-31 of the draft EIR/EA in order to clarify the discussion.

As discussed above, Cal-Am’s ability to deliver water to and transmit water from the Proposed Project site is a limiting factor. As proposed, the temporary, above-ground pipeline that would connect the Proposed Project site with Cal-Am’s existing distribution system at the east end of Hilby Avenue in Seaside would be limited to 3,000 gpm or 13.3 AF per day. This limit will constrain the amount of excess water in the Carmel River Basin that could be diverted for injection and storage in the coastal area of the SGB. Specifically, the average simulated amount of excess water in the Carmel River during the high-flow season that would be diverted for injection as part of the Proposed Project is 960 AF and would range from zero AF to 2,370 AF per year. The median or typical amount of excess flow that would be diverted for injection based on available transmission capacity during the high-flow season is 1,150 AF per year. During the high-flow season, monthly diversions for injection would average between 80 and 240 AF per month. The maximum monthly diversion for injection would be approximately 410 AF.

With the revised logic for the Final EIR/EA, the average simulated amount of excess water in the Carmel River Basin during the high-flow season that would be diverted for injection as part of the Proposed Project is 918 AF and would range from 0 to 2,348 AF per year. The median or typical amount of excess flow that could be diverted from the reach between San Clemente Dam and RM 5.5 for injection based on available transmission capacity is 950 AF per year. During the high-flow season, monthly diversions for injection would average between 80 and 220 AF per month. The maximum monthly diversion for injection would be approximately 410 AF.

Figures 8-20 through 8-31 show the monthly impact of the Proposed Project on Carmel River streamflow at the Narrows, Near Carmel, and Lagoon sites for four types of water year: wet, normal, dry, and critically-dry. Each figure also includes the estimated monthly unimpaired flows for site for reference.


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The following corrections are made to page 8-33 of the draft EIR/EA in order to clarify the mitigation.

Mitigation Measure GWH-4: Operate Project in Compliance With NOAA Fisheries Recommendations and to Reduce Unlawful Diversions MPWMD shall operate the Proposed Project in accordance with all of the bypass terms recommended by NOAA Fisheries in its 2002 report, “Instream Flow Needs for Steelhead in the Carmel River, Bypass Flow Recommendations for Water Supply Projects Using Carmel River Waters.” In addition, Cal-Am should be required to utilize water that is available from the Seaside Basin to help reduce unlawful diversions from the Carmel River. In addition, Cal-Am shall, to the maximum extent feasible, be required to utilize water that is available from the Seaside Basin due to the Proposed Project during the low-flow season from June 1 through November 30 to help reduce unlawful diversions from the Carmel River.

Chapter 10, Noise Proposed Project

Construction Impacts

On page 10-11 of the draft EIR/EA, the text for Mitigation Measure NZ-1a is revised by the MPWMD to reflect the fact that 24-hour-per-day use of certain equipment is necessary to drill the ASR well. The text of the Mitigation Measure is changed to read as follows.

Mitigation Measure NZ-1a: Prohibit Ancillary and Unnecessary Equipment During Nighttime Well Drilling Activities. The project applicant shall ensure that the construction contractor prohibit the use of all ancillary and unnecessary equipment (i.e., backhoe, truck, air compressor, and pump, etc.) during nighttime hours. The only equipment that will be allowed to operate during nighttime activities would be the drilling equipment and well construction equipment; cleanup and other activities will occur only during daytime activities.

Chapter 11, Hazards and Hazardous Materials Impacts and Mitigation Measures

The following corrections are made to page 11-9 and 11-10 of the draft EIR/EA in response to a comment from the Department of Toxic Substances Control.


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Mitigation Measure HAZ-1: Implement UXO MEC Safety Precautions during Grading and Construction Activities at the Project Site. Because of the proposed well site’s location, the following safety precautions are required for onsite activities. The requirements may be modified upon completion of the Munitions Response Remedial Investigation/Feasibility Study (MR RI/FS) process for the munitions response sites.

All personnel accessing the proposed well site will be trained in MEC recognition. This safety training is provided by the Army at no cost to the trainee. Training may be scheduled by contacting Fort Ord BRAC Office, Lyle Shurtleff at 831-242-7919.

If an item is discovered that is or could be MEC, it shall not be disturbed. The item shall be reported immediately to the Presidio of Monterey Police Department at 831-242-7851 so that appropriate U.S. military explosive ordnance disposal personnel can be dispatched to address such MEC as required under applicable law and regulations at the expense of the Army.

Ground disturbing activities, including perimeter fence installation, will be coordinated with U.S. Army Corps of Engineers (USACE) Unexploded Ordnance Safety Specialist so that appropriate construction-related precautions may be provided (Fisbeck pers. comm.). The USACE Pamphlet EP 75-1-2 entitled Munitions and Explosives of Concern (MEC) Support During Hazardous, Toxic and Radioactive Waste (HTRW) and Construction Activities, dated August 1, 2004, which can be found at http://www.usace.army.mil/inet/usace-docs/eng-pamphlets/ep75-1-2/toc.htm shall be followed by the USACE Safety Specialist to determine the type of construction oversight that will be needed based on the type of construction activities to be performed.

Construction activities at the project site are subject to Monterey County Code, Ordinance 5012, Subsection 1 dated 2005, Title 16 “Environment,” Chapter 16.1 “Digging and Excavating on the Former Fort Ord,” which can be found at http://municipalcodes.lexisnexis.com/codes/montereyco. This ordinance prohibits excavation, digging, development, or ground disturbance unless an excavation permit is obtained and the permit requirements are followed.

Chapter 17, Temporary Pipeline Analysis Impacts and Mitigation Measures

On page 17-6 of the draft EIR/EA, the numbering of Mitigation Measure WLD-1 has been revised due to a typographical error.


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Mitigation Measure WLD-12: Remove Trees and Shrubs during the Nonbreeding Season for Most Birds (September 1 Tto February 15)

The following corrections have been made on pages 17-10 and 17-11 regarding the requirement for Mitigation Measures AQ-1 and AQ-2. The reasons for removal are similar to those identified above for the air quality analysis in Chapter 3, “Air Quality.” The temporary pipeline construction will be sufficiently brief, dispersed, and at a distance from sensitive receptors to avoid an elevated health risk.

Impact AQ-2: Exposure of Sensitive Receptors to Elevated Health Risks from Exposure to Diesel Particulate Matter from Construction Activities

Emissions of diesel particulate matter have the potential to result in elevated health risks. The assessment of cancer risk is typically based on a 70-year exposure period. Construction activities are sporadic, transitory, and short-term in nature, and once construction activities cease, so too will emissions from construction. Conversation with MBUAPCD staff indicates that construction activities that occur for less than 1 year will generally not result in any adverse health impacts. Because construction activities would be up to 6 weeks in duration, this impact is considered less than significant. However, to further reduce emissions of diesel PM and associated health risks, Mitigation Measures AQ-1 and AQ-2 are recommended (refer to Chapter 3).

Mitigation: See Mitigation Measures AQ-1 and AQ-2 in Chapter 3. No mitigation is required.

Impact AQ-3: Exposure of Sensitive Receptors to Elevated Health Risks from Exposure to Acrolein Emissions from Diesel Exhaust from Construction Activities

Construction equipment used for the pipeline may be diesel-powered and would therefore emit diesel exhaust. Acrolein is emitted as a product of diesel combustion, where the concentration in diesel exhaust is currently understood to be 0.0035 grams acrolein per gram of ROG emissions. An acute one-hour reference exposure level (REL) of 0.19 µg/m3 has been estimated for acrolein. Since construction would occur at a substantial distance from the nearest sensitive receptor, acrolein emissions would not cause acute health risks. Consequently, this impact is considered to be less than significant. Using methods developed by the MBUAPCD, a screening analysis conducted for project construction indicates that the hazard index for acrolein exposure may exceed 1 at nearby sensitive receptors. Consequently, this impact is considered significant. Implementation of Mitigation Measures AQ-1 through AQ-2 would reduce these impacts to a less-than-significant level.


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Mitigation Measure AQ-1: Use Newer, Cleaner-Burning Engines.

Mitigation Measure AQ-2: Limit Construction Duration.



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Chapter 3 Comment Letters and Responses to Comments

Introduction This chapter documents the responses to public comments on the draft EIR/EA, including those received in writing and those made at the April 17, 2006, public hearing. Copies of the comment letters and comments received at the public hearing are presented in this chapter along with the MPWMD’s responses to each comment.

Comments on the Draft EIR/EA Table 1 lists the individuals and agencies that submitted written and verbal comments on the draft EIR/EA. The comments are divided into government/agency and individual comment letters and then presented alphabetically. Verbal comments presented at the MPWMD board meeting and public hearing on April 17, 2006, are summarized in Public Hearing Comments 12 and 13. The responses to each comment letter appear directly after each comment letter/summary. When comments resulted in changes to the draft EIR/EA, reference is made to the pages in the text of the draft EIR/EA where the changes were made. Changes to the draft EIR/EA are presented in Chapter 2 of this final EIR/EA.


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Monterey Peninsula Water Management District Comment Letters and Responses to Comments

Table 1. List of Individuals and Agencies Commenting on the Draft EIR/EA

Letter Number Date of Comment Letter Commenter Government/Agency Comments Letter 1 May 8, 2006 California Coastal Commission Letter 2 May 22, 2006 California Department of Fish and Game Letter 3 May 4, 2006 Monterey Bay Unified Air Pollution Control District Letter 4 May 8, 2006 Monterey County Department of Health Letter 5 May 4, 2006 National Oceanic and Atmospheric Administration Letter 6 May 22, 2006 National Oceanic and Atmospheric Administration Letter 7 May 9, 2006 State Clearinghouse and Planning Unit Non-Governmental Organization Comments Letter 8 May 8, 2006 California American Water Letter 9 May 4, 2006 Carmel River Steelhead Association Letter 10 April 17, 2006 Carmel Valley Association Late Comment Letter 11 June 1, 2006 Department of Toxic Substances Control Public Hearing Comments Public Hearing Comment 12

April 17, 2006 Robert Greenwood, Carmel Valley Association

Public Hearing Comment 13

April 17, 2006 John Fischer


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Letter 1

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Comment Letter 1—California Coastal Commission, May 8, 2006

Response to Comment 1-1

The comment is introductory. No response is required.


No response is required.


The commission is correct in stating it would have some regulatory authority over the Proposed Project if “development” in the coastal zone were part of the action. Following public review of the draft EIR/EA, MPWMD has concluded that the Proposed Project still will not include development in the coastal zone, and no action will be taken in response to comments that would constitute development in the coastal zone.


Although there will be less river flow to the lagoon during certain periods with the Phase 1 ASR Project, the inference that this lower inflow will result in less volume in the lagoon is questionable and likely erroneous. During winter periods, the amount of water in the lagoon is a function of the elevation of the river outlet at the sand beach barrier. This elevation, while influenced by inflow, responds to a complex interaction of tidal elevations, ocean swell, ocean wind waves, and sediment supply. The maximum difference in inflows with and without ASR diversions will be ± 6.7 cubic feet per second (cfs), which would result in a maximum 10% reduction in inflow when the streamflow is 67 cfs.1 The percentage difference drops to approximately a 3% reduction when streamflow equals 200 cfs, which is generally recognized as the minimum inflow that keeps the lagoon mouth continuously open (James 2005). Thus, within the streamflow range of 67 to 207 cfs, the lower inflow associated with ASR diversions will somewhat hasten closure of the lagoon and result in more volume in the lagoon during the winter period, not less. Generally, the maintenance of a higher base elevation at the outlet channel has become a management goal of the responsible resource agencies and most recently was identified as a key component of future long-term management of the lagoon because water level is directly related to habitat volume and quality in the lagoon (California State Parks et al. 2006).

1 With the proposed operation of ASR Phase 1, no diversions for injection can occur when the streamflow at Highway One drops below 60 cfs, per NOAA Fisheries Recommendations for Bypass Flows. MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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Higher inflows can compromise maintenance of a higher outlet elevation, so slightly lower inflows associated with the ASR Phase 1 Project should result in slightly longer periods of time with the lagoon stage (and hence volume) at higher levels and more aquatic habitat.

On a related subject, the ASR Phase 1 Project will result in higher groundwater elevations and storage in Carmel Valley Alluvial Aquifer Subunits 3 and 4. This beneficial impact extends throughout most of the year in dry and critically dry year types and results in higher inflow to the lagoon during periods when diversions for injection are turned off. For example, as documented in the following excerpted Figures 8-35 and 8-31 from the EIR/EA, in critically dry years the storage during February through May is approximately 1,000 AF greater with the Proposed Project and results in significantly greater monthly inflow to the lagoon during February, March, and April. During these drier periods, the ASR Phase 1 Project indirectly increases inflow to the lagoon, thereby increasing water levels and improving the quality of aquatic habitats in the lagoon.


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The purpose of the Proposed Project is to improve the condition of the Seaside Basin groundwater levels. The MPWMD regularly monitors the basin presently and will continue to do so once the well is installed.


The commenter correctly notes that the Phase 1 ASR Project would not result in changes to Cal-Am’s Carmel River Basin diversion amounts allowed by State Water Resources Control Board (SWRCB) Order 95-10 or to the Cal-Am extractions allowed from the Seaside Basin by the Superior Court’s Final Decision and/or Seaside Basin Watermaster. The primary project purpose and environmental benefit of the Phase 1 Project is to help reduce dry season pumping effects on the Carmel River by maximizing use of the Seaside Basin instead. The Seaside Basin is able to be tapped due to injection of excess winter Carmel River flow into the Seaside Basin via the ASR Project. A secondary benefit of the Proposed Project is improved storage in the Seaside Basin as described in Chapter 8 of the draft EIR/EA.


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The commenter asks if there would be an “impact” of the Phase 1 ASR Project on the initiatives listed in the table below and to describe the impact. By “impact,” the commenter appears to mean impact on the pursuit or implementation of these initiatives by MPWMD and other entities rather than a physical environmental effect. Although the question is beyond the scope of an EIR and is somewhat speculative, a response is provided below as a courtesy.

Initiative Potential Effect of ASR

Remove all or part of San Clemente Dam. No effect on current efforts.

Reduce/eliminate breaching of Carmel River lagoon. No effect on current efforts.

Restore/enhance Carmel River lagoon and environs. See Response to Comment 1-4. Beneficial effect to lagoon re: freshwater inflow and volume.

Reduce Carmel River water withdrawals. Beneficial effect re: reduced dry season withdrawals by Cal-Am in most years.

Enhance Carmel River riparian vegetation. No effect on restoration plans; indirect beneficial effect on water table/root zone.

Water conservation. No effect on program.

City of Sand City desalination plant. No effect on City efforts.

Cal-Am’s proposed desalination plant. No effect on Cal-Am efforts for approvals for Coastal Water Project (CWP). Could result in possible refinement of ASR component of CWP.

Improve/expand wastewater reclamation. No effect on current efforts.

Construct other desalination plants or other new water supply projects.

No effect on current efforts. Phase 1 ASR is viewed as complementary to nearly all projects.

Reduce overpumping; replenish Seaside Basin ASR contributes to Court-identified physical solution to overdraft.

Regarding the Seaside Basin overdraft, the Superior Court’s Final Decision in March 2006 identified ASR as one potential physical solution for the involved parties and Watermaster to pursue. As noted above, the primary focus of the MPWMD Phase 1 ASR Project is to address Carmel River impacts, but some secondary benefits to the Seaside Basin would result. Future phases of the MPWMD ASR program, to be determined in coordination with Cal-Am, the Watermaster, and other entities, would have greater potential to address Seaside Basin issues.


MPWMD thanks the California Coastal Commission for its input regarding the bulldozing activity by the Monterey County Public Works Department at the mouth of the Carmel River lagoon. MPWMD duly notes that this is not a permitted activity and has potential adverse impacts on steelhead. However,


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because the bulldozing activity is not part of the Proposed Project, no change to the environmental document is required.


The following paragraphs address clarifications requested by the commenter about Mitigation Measure GWH-4, “Operate Project in Compliance with NOAA Fisheries Recommendations and to Reduce Unlawful Diversions.” See also Response to Comment 6-3.

First, the “unlawful diversions from the Carmel River” that will be reduced as a result of the proposed ASR Phase 1 Project refer to surface and groundwater diversions from the Carmel River and underlying alluvial aquifer that Cal-Am is presently making in excess of its rights recognized by the SWRCB to meet customer demand. In this regard, SWRCB determined in Order 95-10 that Cal-Am had valid rights to divert up to 3,376 acre-feet per year (AFY) from the Carmel River system. Any diversions from the Carmel River system by Cal-Am in excess of this maximum without additional rights may be considered “unlawful.”2 In Water Year 2005, Cal-Am diverted 10,675 AF from the Carmel River system for customer demand. Therefore, in Water Year 2005, Cal-Am’s unlawful diversions from the Carmel River totaled 7,299 AF. Under Order 95-10, Cal-Am is allowed to produce up to 11,285 AFY from the Carmel River to meet customer demand, without penalty. Under this limit, Cal-Am’s unlawful diversions from the Carmel River would be 7,909 AFY. In the DEIR, the unlawful diversions refer to “diversions in excess of Order 95-10 limitations” and “diversions in excess of established water rights.” The unlawful diversions do not refer to diversions from the Carmel River system made by Cal-Am for MPWMD’s proposed Phase 1 ASR Project that comply with the bypass flows recommended by NOAA Fisheries. The diversions from the Carmel River system for the Phase1 ASR Project would be made under a separate water right that will be held jointly by Cal-Am and MPWMD. This new water right, which is being processed as a change to the water rights currently held by MPWMD for the New Los Padres Reservoir Project (SWRCB Permits 7130B and 20808), is in addition to Cal-Am’s recognized water rights. By implementing the Phase 1 ASR Project and exercising this new right, Cal-Am will be able to reduce its unlawful diversions from the Carmel River during the low-flow months (June through November) by an average of approximately 920 AF.

Second, the language that Cal-Am “should be required to utilize water that is available from the Seaside Basin to help reduce unlawful diversions” refers to how the Proposed Project will be operated in the recovery mode to maximize benefits to the Carmel River and dependent resources during the low-flow season. Specifically, this language refers to how and when the water previously diverted from the Carmel River system and injected into the Seaside Basin will be recovered and used to meet Cal-Am customer demand, instead of diverting from the Carmel

2 Cal-Am’s current diversions of up to 7,909 AFY from the Carmel River in excess of its recognized rights (3,376 AFY) are allowed by SWRCB through the exercise of SWRCB’s discretionary authority and are not technically “unlawful.” These diversions are allowed by SWRCB to protect public health and safety (SWRCB Order No. WR 95-10, July 6, 1995, page 37). MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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River system during the low-flow season. A detailed description of the “operational requirements” governing the recovery operations for the Phase 1 ASR Project is provided in Response to Comment 6-3.

Third, the language refers exclusively to recovery of the “extra injected water” in the Seaside Basin and does not refer to existing or naturally occurring groundwater in the Seaside Basin. It should be noted that in the simulations for the Phase 1 ASR Project, Cal-Am’s production of naturally occurring water from the coastal area of the Seaside Basin is limited to 3,500 AFY (page 8-25), which is consistent with the initial “standard production allocation” specified for Cal-Am from the coastal area of the Seaside Basin in the Final Decision on the Seaside Basin adjudication (Monterey County Superior Court, Case No. M66343, March 27, 2006).

Fourth, the proposed Phase1 ASR Project will not eliminate all of Cal-Am’s unlawful diversions from the Carmel River or reduce Cal-Am’s production from the coastal area of the Seaside Basin to conform to the safe yield estimate determined in the recent adjudication proceedings. Therefore, in addition to MPWMD’s Phase 1 ASR Project, Cal-Am will need to take other measures to reduce its extractions from both the Carmel River and Seaside Groundwater Basins. Cal-Am has proposed a new water supply project called the Coastal Water Project (CWP). The CWP is proposed to comply with the restriction on diversions from the Carmel River specified in SWRCB Order 95-10 and help reduce the overdraft condition in the Seaside Basin. The CWP consists of a seawater desalination plant in Moss Landing, a desalinated water conveyance system, and ASR facilities that would be designed to provide 11,730 AFY. Cal-Am has prepared a Proponent’s Environment Assessment (PEA) and a Conceptual Design Report (CDR) on the CWP. This information is being reviewed by the California Public Utilities Commission (CPUC), the lead agency on the CWP.


The MPWMD thanks the California Coastal Commission for its input regarding the preference of an alternative that would not impact sensitive vegetation. As noted on pages 4-17 and 4-18 of the draft, the Proposed Project would result in the permanent loss of up to 0.7 acre and the temporary disturbance of 0.3 acre of maritime chaparral and sensitive plant species, including Monterey spineflower, sandmat manzanita, Eastwood’s goldenbush, and Kellogg’s horkelia. It should be noted, however, that the Army’s habitat management plan (U.S. Army Corps of Engineers, Sacramento District 1997) took into consideration that this area would eventually be developed within the City of Seaside and that other measures would be in place to compensate for any losses at the proposed well site. As long as the habitat management plan is properly implemented, the loss of these sensitive species will not result in a substantial impact on the environment.

Although Alternative 2 would reduce biological resources impacts, including impacts to the maritime chaparral plant community and the aforementioned special-status plants, this alternative would increase construction-related impacts associated with cultural resources, land use, air quality, and noise. Other impacts


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of Alternative 2 would be similar to the Proposed Project. The decision to select an alternative will be based on which option best meets the needs of the MPWMD to provide a well site while resulting in as few adverse environmental effects as possible.


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Letter 2

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Comment Letter 2—California Department of Fish and Game, May 22, 2006




The commenter’s understanding is correct. The Superior Court decision in the Seaside Basin Adjudication confirms that water stored in the Seaside Groundwater Basin may be recovered and used by the party that stores the water, including by injection. This means that the water stored by MPWMD by injection into the Seaside Groundwater Basin as part of the Phase 1 ASR Project will be available for use by MPWMD. Because the Proposed Project operation is to pump stored water during dry periods and to cause pumping that would otherwise occur from Carmel River system to be reduced, the commenter’s concern is addressed.


MPWMD and the commenter (CDFG) have been meeting to negotiate mutually acceptable resolution of the commenter’s protests to MPWMD’s water rights petitions before the SWRCB to facilitate the Phase 1 ASR Project. The majority of commenter’s concerns have been resolved, and MPWMD anticipates that the remainder will be resolved by the time the ASR Project EIR/EA is certified by the MPWMD Board of Directors.


MPWMD agrees that the water diverted from the Carmel River during high-flow periods by Cal-Am for injection into the Seaside Basin as part of the MPWMD Phase 1 ASR Project should not be used to resolve the overdraft condition in the Seaside Basin and agrees that Cal-Am should be required to reduce its diversions from the Carmel River during low-flow periods when injected water in the Seaside Basin is available for recovery. The commenter’s concern is similar to concern expressed by NOAA Fisheries (see Response to Comment 6-3). To address these concerns, MPWMD in cooperation with CDFG and NOAA Fisheries, has developed a set of explicit rules to govern the proposed recovery operations. These rules “tie” the amount of water that can be recovered in a year to the amount of water that was injected during the year plus injected water in storage and provide an explicit accounting procedure to track water injected, stored, and recovered over time. These rules will be included as a condition in


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the new water right for the Phase 1 ASR Project that will be issued by the SWRCB and held jointly by Cal-Am and MPWMD.

The determination of the amount of water available for recovery will be made at the end of May each year. In the simulation, the determination would be made on June 1 each year. In real-time, it is envisioned that the determination will be made in May by the Memorandum of Agreement (MOA) group (Cal-Am, CDFG, NOAA Fisheries, and MPWMD) as part of the MOA process. In the simulation, once the determination is made, the daily amount of injected water that is targeted for recovery is taken before Cal-Am operates its Carmel Valley wells to meet customer demand. This logic ensures that Cal-Am will reduce its diversions from the Carmel River during the low-flow season when injected water is being recovered for Cal-Am customer use and provide improved flow conditions for the Carmel River steelhead. In real-time, it is envisioned that the targeted recovery amounts that have been determined will be incorporated into the Quarterly Water Supply Strategy and Budgets for Cal-Am that the MOA develops each year in September, December, March, and June. By including the monthly recovery targets from the Seaside Basin in the budgets, Cal-Am’s diversions from the Carmel River during the low-flow season can be reduced accordingly.


The comment does not address the adequacy of the draft EIR/EA. No response is required.


The Proposed Project does not involve the installation of a water pipeline or any construction of new facilities that would result in channel disturbance, but would instead utilize existing facilities. Therefore, the Proposed Project would not require a streambed alteration agreement (SAA).


The U.S. Army obtained a take authorization for 250 acres of projects that included the lands to be occupied by the ASR Project and the Cal-Am temporary pipeline. Any action will be addressed by the Biological Opinions (BOs) obtained by the Army from the USFWS on March 30, 1999, October 22, 2002, and March 14, 2005.


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The text in Mitigation Measure BIO-4 on page 4-21 of the draft EIR has been modified to reflect the need to avoid tree limb and brush removal along the temporary pipeline during inspection, maintenance, and cleaning, as well as during construction. This change is presented in Chapter 2 of this final EIR/EA.




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Comment Letter 3—Monterey Bay Unified Air Pollution Control District, May 4, 2006


The text on page 3-5 of the draft EIR/EA has been corrected to reflect that the North Central Coast Air Basin (NCCAB) is non-attainment transitional, not moderate attainment. This change is presented in Chapter 2 of this final EIR/EA.


The text on page 3-6 of the draft EIR/EA has been corrected to accurately identify the nearest monitoring station in Salinas. This change is presented in Chapter 2 of this final EIR/EA.


The text on page 3-11 of the draft EIR/EA has been revised to indicate that the MBUAPCD Guidelines were adopted in July 2004. This change is presented in Chapter 2 of this final EIR/EA.


The draft EIR/EA indicates Impact AQ-4 is less than significant. However, Mitigation Measures AQ-1 and AQ-2 were included in the draft EIR/EA as recommendations to further reduce diesel particulate matter emissions, particularly those emissions created if well construction were to occur at the alternative well site adjacent to Roger S. Fitch Middle School. Because the effects of the Proposed Project are expected to be less than significant and the alternative well site is not part of the Proposed Project, Mitigation Measures AQ-1 and AQ-2 are no longer being proposed to further reduce adverse effects, and the conclusion for Impact AQ-5 has been modified to indicate that the impact is less than significant. The proposed well site is sufficiently removed from sensitive receptors to not pose a significant health threat. These changes were discussed with MPUAPCD staff prior to completing the final EIR/EA (Getchell pers. comm.). This change is presented in Chapter 2 of this final EIR/EA.


This question and request for conversations with school district personnel prior to construction would be appropriate if the Proposed Project included construction of the well adjacent to Roger S. Fitch Middle School. However, the proposed


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well site is not adjacent to the school and is not expected to have an adverse effect on school children. Therefore, Mitigation Measures AQ-1 and AQ-2 are no longer necessary to further reduce construction-related air emissions.


The comment is noted. Should the Proposed Project require pumps or generators, the MPWMD will contact the MBUAPCD Engineering Division Manager.


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Letter 4

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Comment Letter 4—Monterey County Department of Health, May 8, 2006




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Letter 5

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Comment Letter 5—National Oceanic and Atmospheric Administration, May 4, 2006


The comment does not address the adequacy of the draft EIR/EA. No response is required; a subsequent letter was received on May 22, 2006, with a full set of comments.


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Comment Letter 6— National Oceanic and Atmospheric Administration, May 22, 2006




The commenter correctly notes that the NOAA Fisheries bypass flow recommendations are, in part, based on stream channel conditions. The information used to develop bypass flow recommendations for upstream migration below River Mile (RM) 5.5 was based on analysis of water depths over a series of critical riffles in the lower Carmel River during 1982, 1992, and 1997 (Dettman and Kelley 1986, Dettman 1989, Dettman 1994, Fisheries Working Group 1994, Entrix 2000). While data from these years represent a wide range of streamflows, the streambed was dominated by sand and fine gravel below RM 5.5 during this historical period. Since that time and with few exceptions, the streambed in this reach has coarsened and the low-flow channel has narrowed in many places. Hypothetically, these changes are beneficial in the sense that the flows necessary for maintenance of adequate arrays of water depth and velocity should be lower than originally recommended. However, as the commenter notes, streambed conditions are variable depending on the supply and transport of sand to the channel. In response to the commenter’s recommendation for monitoring and modifying channel conditions below RM 5.5, MPWMD believes this is appropriate as long as there is an opportunity and mechanism to lower the bypass flow recommendation, if streambed and channel conditions are maintained and persist in a favorable condition. For example, with the improved, existing streambed conditions, bypass flows of less than 60 cfs may provide adequate passage conditions.

To address these issues MPWMD proposes to adopt Mitigation Measure AR-1, which is presented in Chapter 2 of this final EIR/EA and added to page 5-21 of the draft EIR.

Regarding the commenter’s recommendation that it will be necessary to examine the adequacy of the bypass flows for spawning and rearing habitats below RM 5.5, MPWMD notes that no specific study has been conducted relating spawning habitats or rearing habitats to streamflow in the lower section of the river. Considering this basic lack of information, MPWMD believes the best approach is to continue monitoring the number of steelhead nests in this reach and counts of the number of juvenile fish rescued in the reach below RM 5.5, as part of the existing Mitigation Program for the MPWMD Water Allocation Program. With sufficient time, this monitoring will yield additional information on the adequacy of


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streamflow and channel conditions in providing suitable spawning and rearing habitats for early phases in the steelhead life history in this reach of the river.


NOAA Fisheries’ concerns regarding assurance that the proposed Phase 1 ASR Project will operate as designed and will benefit the Carmel River and dependent resources as described in the DEIR/EA are shared by the CDFG. Specifically, these agencies want assurances that, not only will the Proposed Project comply with the bypass flow requirements recommended by NOAA Fisheries in their June 2002 report, but also that the “excess”3 water diverted for injection into the Seaside Basin during high-flow periods will be used to benefit the Carmel River system and steelhead during low-flow season. More specifically, the agencies want a “guarantee” that, over time, the amount of water diverted from the Carmel River for injection into the Seaside Basin during the December – May period will be offset by the amount of additional water pumped by Cal-Am from the coastal area of the Seaside Basin during the June – November period. By having this additional water available for pumping from the Seaside Basin in the low-flow season and assuming the same customer demand, Cal-Am would be able to reduce its diversion from the Carmel River system during the low-flow season by a commensurate amount and provide improved flow conditions for steelhead.

In meetings with NOAA Fisheries and CDFG in Spring/Summer 2006, it became clear that more explicit rules governing when and how the injected water in the Seaside Basin would be recovered were needed, and that these “recovery rules” should be incorporated into the new water right permit sought by MPWMD and Cal-Am for the Phase 1 ASR Project. These recovery rules would be analogous to the bypass flow requirements recommended by NOAA Fisheries for diversions for injection. The recovery rules were developed by MPWMD staff following discussions with NOAA Fisheries and CDFG staff in June 2006 and incorporated into MPWMD’s operations model, CVSIM3. The rules and revised computer code were tested and a new simulation, Run #7, was generated on June 25, 2006. The recovery rules are summarized below.

Phase 1 ASR Project Recovery Rules

The 6-month recovery period, June 1 through November 30, used in the original simulation (Run #4) was retained. During this period, the annual amount of water determined to be available for recovery at the end of May each year was uniformly distributed. For example, if it was determined that 1,200 AF were available for recovery during the upcoming recovery season, then 200 AF would be recovered each month between June and November. The daily amount that would be recovered from the Seaside Basin by MPWMD’s Phase 1 ASR wells and provided to Cal-Am for customer service, instead of Cal-Am pumping its

3 Excess water refers to groundwater in the alluvial aquifer underlying the Carmel River that can be diverted by Cal-Am without lowering the mean daily streamflow in the Carmel River below the daily bypass flows recommended by NOAA Fisheries in their June 3, 2002 report, Instream Flow Needs for Steelhead in the Carmel River, Bypass Flow Recommendations for Water Supply Projects Using Carmel River Waters. MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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wells in the Lower Carmel Valley, would vary between 6.5 and 6.7 acre-feet per day (AFD), depending on the number of days in the respective month.

The annual amount of water available for recovery will depend on (a) the amount of water injected into the basin during the preceding injection season, (b) the cumulative amount of water injected into the basin during previous injections seasons that has not been recovered and remains in storage, (c) the annual recovery target specified, and (d) the maximum carryover amount specified.

The amount of water injected into the basin during the preceding injection season will vary depending on streamflow conditions in the Carmel River mainstem and the reach of the Carmel River from which the diversions are made. For the simulation, mean daily streamflows based on historical mainstem and tributary flows in the Carmel River Basin between October 1, 1957, through September 30, 2002, were used. For the revised simulation, it was assumed that all diversions from the Carmel River by Cal-Am for the Phase 1 ASR Project would come from wells in the reach between San Clemente Dam and RM 5.5. As explained in Response to Comment 9-2, the bypass flow requirements in this reach are greater than the requirements in the reach between RM 5.5 and the lagoon. Accordingly, less water would be available for diversions from the Carmel River for injection into the Seaside Basin in the revised simulation. As originally simulated, the amount of water available annually for injection from the reach below RM 5.5 would average 963 AF and range from 0 to 2,374 AF. As revised, the amount of water available annually for injection from the reach above RM 5.5 would average 918 AF and range from 0 to 2,348 AF.

The cumulative amount of water injected into the basin during previous injection seasons that has not been recovered and remains in storage is tracked during the simulation and represents the amount of carryover storage in the Seaside Basin that is available at the end of each injection season due to the Phase 1 ASR Project. If available, this storage can be used to meet the specified recovery target. Similarly, this storage can be added to, if the amount injected during the previous injection season exceeds the specified recovery target.

For the revised simulation, the annual recovery target was specified at 1,500 AFY. This target was selected through an iterative process so that the average annual amount of water recovered from the Seaside Basin and provided to Cal-Am (i.e., 916 AFY) approximated the average annual amount of water diverted from the Carmel River by Cal-Am for injection (i.e., 918 AFY) over the 45-year simulation period. In the revised simulation, the amount of water recovered annually from the Seaside Basin would range from 31 to 1,475 AF.

For the revised simulation, the maximum carryover amount specified was 5,000 AF. This maximum acts as an upper bound on the amount of injected water that is allowed to accumulate in the Seaside Basin. In the simulation, the 5,000 AF maximum was selected to provide 1,000 AFY for the 5-year drought of record in the Monterey Peninsula area (i.e., Water Years 1987 through 1991). If a series of wet years occur, diversions for injection would be sufficient to meet the 1,500 AF annual recovery target, and carryover storage would accumulate over time, eventually exceeding 5,000 AF at the end of the injection season. In this


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situation, the injected water in storage in the Seaside Basin in excess of the 5,000 AF will be added to the annual recovery target amount for the upcoming recovery season and distributed uniformly over the 6-month recovery period. For example, if carryover storage was 5,800 AF at the end of the preceding injection season, then the recovery target for the upcoming recovery season would be 2,300 AF (1,500 AF target goal + 800 AF excess storage), with approximately 380 AF recovered each month for 6 months.

The determination of the amount of water available for recovery is made at the end of May each year. In the simulation, the determination is made on June 1 each year. In real-time, it is expected that the determination will be made in May by the MOA group (Cal-Am, CDFG, NOAA Fisheries, and MPWMD) as part of the MOA process. In the simulation, once the determination is made, the daily amount of injected water that is targeted for recovery is taken before Cal-Am operates its Carmel Valley wells to meet customer demand. This logic ensures that Cal-Am will reduce its diversions from the Carmel River during the low-flow season when injected water is being recovered for Cal-Am customer use. In real-time, it is expected that the targeted recovery amounts that have been determined will be incorporated into the Quarterly Water Supply Strategy and Budgets for Cal-Am that the MOA develops each year in September, December, March, and June.

The revised logic, by “tying” the amount of water that can be recovered in a year to the amount of water that was injected during that year plus injected water in storage, provides an explicit accounting procedure to track water injected, stored, and recovered over time. This procedure can be used to ensure that water diverted from the Carmel River for injection during the high-flow winter months is used to reduce Cal-Am’s diversions from the Carmel River during the low-flow summer months.

Based on the revised simulation for the Phase 1 ASR Project, annual injections would average 918 AFY and annual recoveries would average 916 AFY. With the Phase 1 ASR Project, Cal-Am’s diversions from the Carmel River for customer service would average 9,885 AFY. Without the Phase 1 ASR Project (i.e., No-Project), Cal-Am’s diversions from the Carmel River for customer service would average 10,521 AFY. This reduction in Cal-Am’s diversions from the Carmel River for customer service would occur during the June through November period and range from a 98 to 121 AF reduction per month, thus providing a benefit during the most critical months of the year. It should be noted that with the Phase 1 ASR Project, Cal-Am would also divert an average of 918 AFY of excess water from the Carmel River during the high season for injection. This diversion would be made under a new water right held jointly by Cal-Am and MPWMD. Diversions by Cal-Am for injection during the high-flow season would not count against the 11,285 AFY diversion limit specified in SWRCB Order 95-10 for Cal-Am’s diversions from the Carmel River for customer service.

MPWMD is confident that the recovery rules developed in cooperation with CDFG and NOAA Fisheries will provide adequate assurance to the agencies that the proposed Phase 1 ASR Project will be operated as designed and will provide


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the benefits described in the DEIR/EA to the Carmel River and dependent resources, including the listed Carmel River steelhead population. The recovery rules will be included as a condition of the new water right that will be issued by the SWRCB and held jointly by Cal-Am and MPWMD.

The revised operations described above would not change any of the environmental conclusions described in the draft EIR. The final EIR will include revised text for Chapter 8, “Modeling Assumptions,” to describe the revised operating procedures.


The comment expresses support of the Proposed Project and does not address the adequacy of the draft EIR/EA. No response is required.


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Letter 7

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Comment Letter 7—State Clearinghouse and Planning Unit, May 9, 2006




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Letter 8

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Comment Letter 8—California American Water, May 8, 2006




The commenter correctly notes that the Cal-Am system as currently configured would not be capable of delivering up to 3,000 GPM on a consistent basis for ASR injection. MPWMD, Cal-Am, and their respective technical consultants have met on several occasions in spring–summer 2006 to discuss alternative modifications to the Cal-Am delivery system that would allow additional diversions to reliably serve the Phase 1 ASR Project. Based on assurances received from Cal-Am to date, it is expected that this ongoing analysis will result in Cal-Am making system modifications that will allow for such diversions to occur as designed and described in the draft EIR/EA.


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Letter 9


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Comment Letter 9—Carmel River Steelhead Association, May 4, 2006


The commenter correctly notes that the success of adult upstream migration is affected by the combination of streamflow, channel configuration, and substrate conditions. The commenter correctly notes that NOAA Fisheries bypass flow recommendations were based on past studies under varying streambed conditions and channel configurations. There is agreement that the channel conditions change from year-to-year and that bypass flows should be set to provide adequate minimum passage conditions, recognizing that conditions may change. To this end, the commenter’s recommendation for a mitigation measure “to thoroughly evaluate all critical riffles prior to each ASR season and the flows necessary for passage” is reasonable. However, it is not reasonable to constantly monitor each critical riffle during the migration period. Instead, a reference site, such as the MPWMD gaging station at the Highway One Bridge or the USGS Near Carmel gaging station, should be used for this purpose. The commenter’s concerns and recommendations parallel those of NOAA Fisheries (Comment 6-2). Please refer to Response to Comment 6-2.

MPWMD agrees that no operational standard should be employed that changes the status of the Carmel River steelhead from threatened to endangered or that results in extinction. MPWMD notes that a primary purpose of the Phase 1 ASR Project is to begin reversing the water extractions that continue to imperil the steelhead population. With the proposed ASR Project, this is accomplished by diverting water during periods of surplus (December through May), storing this water in the Seaside Groundwater Basin, and recovering this water primarily during the summer–fall period. The Phase 1 ASR Project thereby reduces diversions from the Carmel River Basin during periods when existing diversions: (1) severely limit other phases of the steelhead lifecycle, (2) continue to reduce the juvenile population, and (3) threaten the survival of the adult steelhead population.


The commenter correctly notes that the analysis in the DEIR assumed that the water diverted from the Carmel River system for injection into the Seaside Basin for the Phase 1 ASR Project would be pumped from Cal-Am’s farthest downstream well (i.e., Rancho Cañada well at RM 3.13). MPWMD agrees that this assumption is inconsistent with actual operations and Condition 5 of SWRCB Order No. WR 95-10, which requires Cal-Am to satisfy the water demands of its customers by extracting water from its downstream wells to the maximum practicable extent. To correct this inconsistency and ensure that the modeled flows conformed to actual operations, MPWMD revised its operations model (i.e., CVSIM3) and generated a new simulation for the proposed Phase 1 ASR Project. Specifically, the logic in the model was revised to comply with


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Condition 5 of Order 95-10 and require that the water from the Carmel River system needed to meet Cal-Am’s customer demand would be produced from Cal-Am’s most downstream wells and that the water diverted from the Carmel River system during the high-flow period for injection would be produced from the next upstream wells.

It should be noted that the bypass flow requirements in the reach between San Clemente Dam and RM 5.5 are greater than the requirements in the reach between RM 5.5 and the lagoon. By moving the diversion point for water for injection from the reach below RM 5.5 to the reach above RM 5.5, less water was available for injection. As originally simulated, an average of 963 AFY was available for injection from the reach below RM 5.5. With the revised logic and the requirement that the water for injection would be pumped from the reach above RM 5.5, an average of 918 AFY was available for injection.

The revised simulation results for the Phase 1 ASR Project were compared with the original simulation results and do not differ significantly. Because the amount of water available for diversion from the Carmel River system for injection is slightly less, less water is injected into the Seaside Basin and available for recovery during the low-flow season.


The statement that “flows during the last 30 years have not been adequate to support a self-sustaining steelhead population” refers to the impaired flows that have occurred in the Carmel River during the last 30 years (i.e., 1975 through 2005) and the decline in the steelhead population that has been observed. As explained in Appendix A of the draft EIR, Carmel River/Freshwater Aquatic Life, the current run of 500 to 1,000 fish has been maintained by implementing efforts to reconfigure Cal-Am’s diversions, rescuing juvenile fish, carrying out a brood stock program during the 1987 to 1991 drought, and constraining water production in the Carmel River Basin (page A-13). The impairment to the natural flows in the Carmel River during the 1975 to 2005 period is due primarily to Cal-Am’s dam operations and groundwater diversions by Cal-Am and non Cal-Am well owners.

The statement that “flows during the last 30 years have not been adequate to support a self-sustaining steelhead population” is supported by field observations and does not rely on models or the distribution of water year types during the last 30 years. As explained in Chapter 8, “Surface and Groundwater Hydrology and Water Quality,” the 45-year period of record used in the impact analyses (i.e., Water Years 1958 to 2002) is considered representative of the range of hydrologic extremes expected over the life of the Proposed Project. Specifically, this period includes a short-duration, severe drought period (Water Years 1976– 1977) and a longer duration, less severe drought period (Water Years 1987– 1991). The selected period of analysis also includes extremely wet years such as Water Years 1983, 1995, and 1998. Note that the simulation model operates on a daily time-step and over the 45-year period covers a span of approximately 16,425 days. In this regard, it is believed that the period is sufficiently long


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enough to determine the water supply performance of the proposed Phase 1 ASR Project and its impact on the Carmel River steelhead run.


MPWMD acknowledges that there is inherent uncertainty in predicting future events and effects on complex ecosystems like the Carmel River. However, MPWMD believes the conclusions described in the draft EIR are accurate and is confident of the reliability of computer simulation results as relative performance measures. The CVSIM model has been evaluated by independent experts who determined it to be an acceptable predictive tool. Regarding the “reliability” of the five assumptions listed, the following information is provided.

1) The assumption that the amount of injected water in the Seaside Basin that would be available each year for recovery would be uniformly distributed during the June 1 through November 30 “recovery” period was made to facilitate the comparison between the No-Project and Phase 1 ASR simulation results. In reality, it is envisioned that the interagency management group that meets each year to negotiate the MOA governing Cal-Am’s operations during the low-flow season (i.e., usually May through December) will also determine the amount of injected water available for recovery and the daily distribution that will provide the greatest benefit to the Carmel River system and dependent steelhead resource. Decisions by the MOA group, which is presently composed of staff from Cal-Am, CDFG, NOAA Fisheries, and MPWMD, will be based on current “real-time” conditions. For example, if it is determined that 1,200 AF are available for recovery during the 6-month recovery period, then assuming a “uniform” distribution, 200 AF would be produced each month between June and November and approximately 6.5 AF would be pumped from the coastal portion of the Seaside Basin rather than the from the Lower Carmel each day between June and November. However, based on actual conditions, the MOA group could decide to apply a non-uniform distribution. For example, the 1,200 AF available for recovery could be ramped down with 400 AF pumped in June; 300 AF pumped in July; 200 AF pumped in August; and 100 AF pumped in September, October, and November. Under this distribution, daily pumping from the Seaside Basin would vary from 13.3 AF in June to 3.2 AF in October and would provide greater benefits during the early summer months.

2) The assumption that the proposed ASR wells will inject 13.3 AFD, which is equivalent to 3,000 gallons per minute (gpm), is based on experience with MPWMD’s existing Santa Margarita Test Injection Well (SMTIW) and proposed improvements to Cal-Am’s distribution system. Presently, the SMTIW is capable of injecting up to 1,250 gpm or 5.5 AFD. For the proposed Phase 1 ASR Project, it is planned that a second larger ASR well will be constructed near the existing SMTIW. The second well (i.e., ASR Well #2) will be a larger diameter well with greater capacity and should be able to inject up to 1,750 gpm or 7.7 AFD. As designed, both wells will operate together in the injection mode during the injection season and should be capable of injecting 13.3 AFD into the Seaside Basin.


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3) The assumption that Cal-Am can move 13.3 AFD to the proposed Phase 1 ASR site for injection and move 13.3 AFD of recovered water from the Phase 1 ASR site to its distribution system for delivery to its customers is based on discussions with Cal-Am and its consultants, RBF Consulting. RBF has modeled Cal-Am’s distribution system and identified areas where potential problems could occur with the proposed Phase 1 ASR Project. Various options have been developed to address these problem areas and ensure Cal-Am’s ability to reliably provide water to its customers and to the proposed ASR site for injection and subsequent recovery. As described in the draft EIR, Cal-Am is proposing to construct a temporary aboveground pipeline that would connect the existing SMTIW and proposed ASR Well #2 to the Hilby distribution main (page 2-16). This temporary 16-inch diameter pipeline would be installed parallel and to the west of the existing General Jim Moore Boulevard alignment and would be approximately 6,700 feet in length. A permanent pipeline will be installed once the new road alignment is finalized and other long-term water supply issues are resolved. The temporary pipeline will be in place no more than 5 years and will be sized to transmit 3,000 GPM (13.3 AFD) to and from the site.

4) The assumption that annual subsurface inflow into the coastal area of the Seaside Basin from upgradient inland areas is approximately 4,955 AFY is based on findings from previous hydrogeologic investigations of the Seaside Groundwater Basin. These previous estimates were based on an application of Darcy’s Law, which relates subsurface flow to cross-sectional area, gradient, and hydraulic conductivity of the aquifer material. As explained in the DEIR, these earlier subsurface inflow estimates were compared to updated estimates developed for the Seaside Basin adjudication proceedings (i.e., Seaside Groundwater Basin: Update on Water Resource Conditions [Yates et al. April 2005]). The subsurface inflow used in previous simulations (i.e., 4,995 AFY) is between the range developed by Yates and others (i.e., 4,000–5,740 AFY) and was retained for the Phase 1 ASR Project simulations.

5) The incremental yield associated with the proposed Phase 1 ASR Project was computed by comparing the Cal-Am’s average annual production from the coastal area of the Seaside Basin with the Phase 1 ASR Project (4,720 AFY) with Cal-Am’s average annual production from the coastal area of the Seaside Basin with the No-Project (3,670 AFY). The increase in average annual production (i.e., 1,050 AFY) was due to the increased recharge to the basin that resulted from the injection operations. With this increased recharge, it was possible to increase simulated extractions without further depleting storage. The Phase 1 ASR Project yield (4,720 AFY) was determined by a series of trial simulations. In each successive simulation, the “target” parameter for Cal-Am’s production from the coastal area of the Seaside Basin was incrementally increased until the amount of usable storage in the coastal area of the basin approximated the minimum usable storage simulated for the No-Project alternative (i.e., 119 AF at the end of November 1991).


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MPWMD agrees that the two statements noted in the comment are confusing and could create doubt. MPWMD therefore hereby removes these statements from page 8-23 of the draft EIR based on water rights protest dismissal negotiations with CDFG and NOAA Fisheries. These revisions are presented in Chapter 2 of this final EIR.

As part of these discussions, additional assurances have been made to ensure benefit to the Carmel River as the primary purpose of the Phase 1 ASR Project. These are reflected in revised text and mitigation measures in the final EIR as well as recommended conditions on a water rights permit for the Phase 1 ASR Project to be issued by the SWRCB. MPWMD’s objective is to divert excess water from the Carmel River system during high-flow winter and spring months for injection and storage in the Seaside Groundwater Basin so that increased pumping from the Seaside Basin is possible and allows corresponding reductions in diversions from the Carmel Valley alluvial aquifer during the low-flow summer and fall months to maintain groundwater storage and surface water flow in the lower Carmel Valley. Similarly, the excess water diverted from the Carmel River system during high-flow periods should be used exclusively to benefit the Carmel River system and dependent resources during low-flow periods. By utilizing the water injected in the Seaside Basin and reducing diversions by Cal-Am from the Carmel River system for customer water demand during the low-flow season, groundwater storage in the Carmel Valley will be maintained and Carmel River streamflow will last longer and flow farther. This increased flow will provide both immediate and long-term benefits to the Carmel River steelhead run (e.g., less time to refill the aquifer and initiate flow to the ocean in the fall).


In CVSIM3, percolation of Carmel River streamflow through the bed of the Carmel River was simulated using a relationship between streamflow and infiltration losses developed by the USACE in their Feasibility Report on Water Resources Development for the Carmel River (May 1981, Volume II, Appendix C, Hydrology and Hydraulics). The relationship was developed for the reach between San Clemente Dam and the Carmel River near the Carmel gaging station. The monthly relationship is represented by a family of three curves that relate to aquifer storage: (1) zero percolation rate when the aquifer is full, (2) medium percolation rate when the aquifer is drawn down 1,000 AF, and (3) maximum percolation rate when the aquifer is drawn down more than 3,000 AF. As an example, when the aquifer is drawn down 1,000 AF and monthly streamflow is 2,000 AF, monthly percolation is estimated to be approximately 600 AF. Similarly, when the aquifer is drawn down more than 3,000 AF and monthly streamflow is 2,000 AF, monthly percolation is estimated to be 1,700 AF. Thus, the lag time in percolation has been taken into account in the simulation model.


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The commenter’s concern is that Cal-Am would not be required to reduce its diversions from the Carmel River during low-flow periods when injected water in the Seaside Basin is available for recovery and, as a result, the Proposed Project would not benefit the Carmel River steelhead as described in the draft EIR/EA. This concern is similar to concerns expressed by NOAA Fisheries (see Response to Comment 6-3) and CDFG (see Response to Comment 2-4). To address these concerns, the MPWMD, in cooperation with CDFG and NOAA Fisheries, has developed a set of explicit rules to govern the proposed recovery operations. These rules “tie” the amount of water that can be recovered in a year to the amount of water that was injected during the year plus injected water in storage and provides an explicit accounting procedure to track water injected, stored, and recovered over time. These rules will be included as a condition in the new water right for the Phase 1 ASR Project that will be issued by the SWRCB and held jointly by Cal-Am and the MPWMD.

The determination of the amount of water available for recovery will be made at the end of May each year. In the simulation, the determination would be made on June 1 each year. In real time, it is envisioned that the determination will be made in May by the MOA group (Cal-Am, CDFG, NOAA Fisheries, and the MPWMD) as part of the MOA process. In the simulation, once the determination is made, the daily amount of injected water that is targeted for recovery is taken before Cal-Am operates its Carmel Valley wells to meet customer demand. This logic ensures that Cal-Am will reduce its diversions from the Carmel River during the low-flow season when injected water is being recovered for Cal-Am customer use. In real time, it is envisioned that the targeted recovery amounts that have been determined will be incorporated into the Quarterly Water Supply Strategy and Budgets for Cal-Am that the MOA develops each year in September, December, March, and June. Based on actual conditions, it should be noted that the MOA group could decide to extend the recovery period into December. This decision would be subject to the availability of injected water in storage.


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Comment Letter 10—Carmel Valley Association, April 17, 2006


It would be more cost effective to install a permanent pipeline to serve the Proposed Project rather than a temporary pipeline; however, several constraints preclude pursuing this option at the present time. First and foremost, the permanent location for this pipeline is slated for the right-of-way of the proposed future realignment of General Jim Moore Boulevard. Permanent location of this pipeline is not possible along the present alignment of this road. Access to the future realignment is currently not available and will not be available until construction of the realigned road is underway, which is still at least several years away. Issues including clearance for MEC and the land transfer schedule from the Army to the City of Seaside need to be resolved before road realignment work and installation of utilities infrastructure can begin in the area where the permanent pipeline is to be placed. In addition, the size for a permanent pipeline in the realigned roadway will be a function of future water supply project decisions that will be based on analyses that have not yet been completed and are not expected to be completed in time for the scheduled startup of the Phase 1 ASR Project next year.


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Comment Letter 11—Department of Toxic Substances Control, June 1, 2006


The text on page xix of the draft EIR/EA has been corrected to modify the phrase “unexploded ordnance” (UXO) to “Munitions and Explosives of Concern” (MEC). This change is made to the first occurrence of UXO in the Acronyms section of the EIR; all subsequent occurrences are also hereby revised. This change is presented in Chapter 2 of this final EIR/EA.


The text on pages 11-9 and 11-10 of the draft EIR/EA has been corrected to expand Mitigation Measure HAZ-1. This change is presented in Chapter 2 of this final EIR/EA.


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Public Hearing Comment 12—Robert Greenwood, Carmel Valley Association, April 17, 2006

Summary

The commenter requests that the final EIR address the cost of installing a permanent pipeline connection to the Cal-Am system, large enough to serve Phase 2 of the project.

Response to Comment 12

Please see Response to Comment 10-1.


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Public Hearing Comment 13—John Fischer, April 17, 2006

Summary

The commenter expresses thanks for receiving an answer to a previous question about the old Monterey Bay oil storage plant.

Response to Comment 13

Because the comment does not address the adequacy of the draft EIR/EA, no response is required.


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Chapter 4 Revised Mitigation Monitoring Plan

CEQA requires that when a lead agency makes findings of significant effects identified in an EIR, it must also adopt a program for reporting and monitoring mitigation measures that were adopted or made conditions of project approval. NEPA requires that the lead agency must include a monitoring and enforcement program for each mitigation measure identified in an EA or Environmental Impact Statement. The objectives of the monitoring are to:

ensure that mitigation measures are properly implemented,

provide feedback to agency staff and decision makers about the effectiveness of their actions,

provide learning opportunities for improving mitigation measures on future projects, and

identify the need for enforcement action before irreversible environmental damage occurs.

This Mitigation Monitoring Plan (MMP) is designed to ensure that the mitigation measures identified in the EIR/EA are fully implemented. The MMP contains each mitigation measure found in the EIR/EA and is organized by topic in the same order as the contents of the EIR/EA. The agency responsible for monitoring is identified for each measure. The MMP will be considered by the MPWMD in conjunction with project review.

Vegetation and Wildlife Mitigation Measure BIO-1: Minimize or Prevent Disturbance to Adjacent NRMA To prevent disturbance of the adjacent NRMA, management measures will be carried out during project construction and operation to minimize construction effects and the potential for introducing invasive nonnative species. The construction contractor will implement BMPs to prevent the spread outside the construction area of construction materials, oil and fuel, sidecast soil, dust, or water runoff. All invasive nonnative plants, such as iceplant or pampas grass, will be removed from the construction area prior to site disturbance to avoid the spread of plant fragments or seeds. A firebreak consistent with the requirements of the Presidio of Monterey Fire Department and acceptable to the City of


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Monterey Peninsula Water Management District Revised Mitigation Monitoring Plan

Seaside Fire Department will be located and maintained by MPWMD between the well site and the adjacent NRMA.

Monitoring: MPWMD is responsible for ensuring that this mitigation measure is implemented. MPWMD will conduct on-site monitoring during construction.

Mitigation Measure BIO-2: Remove Trees and Shrubs during the Nonbreeding Season for Most Birds (September 1 To February 15) Clearing of the site for inspection, maintenance and cleaning, and construction of the well and associated facilities and the pipeline, and subsequent inspection and maintenance and cleaning activities will result in the removal of trees and shrubs that provide suitable nesting habitat for migratory birds. To avoid the loss of active migratory bird nests, tree and shrub removal will be conducted only during the nonbreeding season for migratory birds (generally September 1 to February 15). Removing woody vegetation during the nonbreeding season will ensure that active nests will not be destroyed by removal of trees supporting or adjacent to active nests.

Monitoring: Prior to initiation of construction activities, MPWMD will ensure that this mitigation measure is implemented. MPWMD is responsible for ensuring compliance for the duration of the project.

Aquatic Resources Mitigation Measure AR-1: Conduct Annual Survey Below River Mile 5.5 and Monitor River Flow in January–June Period. Even though the project impact is beneficial and no mitigation is required, the following mitigation is proposed to ensure adequate monitoring of the lower Carmel River. At the beginning of each diversion season and following each storm with a peak flow greater than 3,000 cfs, MPWMD shall conduct a survey of the river channel below RM 5.5 and identify five specific locations where low flows or the channel configuration could potentially block or impair upstream migration of adult steelhead.1 During the period from December 1 through May 31 when water is being diverted from the Carmel River and injected into the Seaside Groundwater Basin, MPWMD shall monitor flow at the Highway One Bridge, and water currents, depths, and channel configuration at each of the five sites previously identified. If evidence of impairment or blockage is found, MPWMD shall cease diverting until flow increases or until the channel configuration is modified so as to alleviate the blockage or impairment. In the event that channel conditions improve or deteriorate for more than two seasons, the bypass flow criteria shall be reexamined and may be modified by among between NOAA Fisheries, CDFG, and the MPWMD.

1 Potential impairment or blockage shall be monitored by measuring water depths at the shallowest points at 2-foot intervals along the crest of riffles. For the purpose of monitoring and assessing the need for channel modifications, the potential for impairment and/or blockage shall be based on the following criteria: blockage, if the width and depth of a continuous section is less than 5 feet wide and > 0.6 feet deep; impaired, if the width and depth of a continuous section is five to ten feet wide and > 0.6 feet deep, and no impairment, if the width and depth of a continuous section is ≥ 10 feet wide and > 0.6 feet deep. MPWMD Phase 1 Aquifer Storage and Recovery Project Final Environmental Impact Report/Environmental Assessment

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Monitoring: MPWMD is responsible for ensuring that this mitigation measure is implemented. MPWMD will conduct on-site monitoring during project operation.

Mitigation Measure AR-2: Cooperate to Help Develop a Project to Maintain, Recover, or Increase Storage in Los Padres Reservoir and If Needed, Continue Funding Program to Rescue and Rear Isolated Juveniles To ensure the continued benefit of the Proposed Project to the Carmel River and dependent resources during future low-flow periods, MPWMD will encourage and work with Cal-Am, CDFG, and NOAA Fisheries to investigate and develop a project to improve summer flows and the quality of releases by maintaining, recovering, or increasing storage capacity in the existing Los Padres Reservoir. MPWMD will provide staff expertise and data, as requested. Cal-Am, as owner and operator of Los Padres Dam and Reservoir, is responsible for maintenance of the dam and compliance with existing regulations, including water right conditions. MPWMD will request that Cal-Am develop an updated elevation-capacity curve for Los Padres Reservoir that provides current estimates of the amount of storage capacity available at various elevations in the reservoir area.

In the meantime, MPWMD will continue funding and operation of its program to rescue and rear juvenile steelhead that are stranded downstream of the USGS gaging station at Robles del Rio (RM 14.4). This program is part of MPWMD’s mitigation program that was adopted in 1990 when the MPWMD Board certified the MPWMD Water Allocation Program EIR. Without significant progress in maintaining storage capacity in Los Padres Reservoir, the rescue program will be needed in most years.

Monitoring: Cal-Am is responsible for ensuring that this mitigation measure is implemented. Cal-Am will conduct on-site monitoring of Los Padres Reservoir during project operation. MPWMD will provide staff expertise and data, as requested, and continue funding and operation of its program to rescue and rear juvenile steelhead.

Cultural Resources Mitigation Measure CR-1: Stop Work If Buried Cultural Deposits Are Encountered during Construction Activities If buried cultural resources such as chipped stone or groundstone, historic debris, building foundations, or human bone are inadvertently discovered during ground-disturbing activities, the construction contractor will stop work in that area and within a 100-foot radius of the find until a qualified archaeologist can assess the significance of the find and, if necessary, develop appropriate treatment measures. Treatment measures typically include avoidance strategies or mitigation of impacts through data recovery programs such as excavation or detailed documentation.


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Mitigation Measure CR-2: Stop Work If Human Remains Are Encountered during Construction Activities If human skeletal remains are encountered, the construction contractor will notify MPWMD and the county coroner immediately. MPWMD will ensure the construction specifications include this order.

If the county coroner determines that the remains are Native American, the coroner will be required to contact the Native American Heritage Commission (pursuant to Section 7050.5 [c] of the California Health and Safety Code) and the County Coordinator of Indian Affairs. A qualified Jones & Stokes archaeologist will also be contacted immediately.

If human remains are discovered in any location other than a dedicated cemetery, there will be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until:

the coroner of the county has been informed and has determined that no investigation of the cause of death is required; and

if the remains are of Native American origin:

the descendants of the deceased Native Americans have made a recommendation to the landowner or the person responsible for the excavation work for means of treating or disposing of with appropriate dignity the human remains and any associated grave goods as provided in Public Resources Code Section 5097.98; or

the NAHC was unable to identify a descendent or the descendent failed to make a recommendation within 24 hours after being notified by the commission.

According to the California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). Section 7050.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If the remains are determined to be Native American, the coroner must contact the NAHC.



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Surface and Groundwater Hydrology and Water Quality

Mitigation Measure GWH-1: Comply with Performance Standards in NPDES Permits All construction activities, vehicle storage, and discharges associated with project construction and operation, including well discharges, shall be accomplished in accordance with NPDES permits from the RWQCB to ensure no degradation of surface or groundwater quality. All performance standards contained in the permit will be met.


Mitigation Measure GWH-2: Operate Project in Compliance with SWRCB and DHS Policies MPWMD shall operate the Proposed Project in compliance with the SWRCB's Anti-Degradation Policy (Resolution 68-16), and applicable DHS regulations regarding drinking water quality.


Mitigation Measure GWH-3: Modify Project Operations as Required by Results of Monitoring Groundwater conditions shall be tracked via the MPWMD’s existing monthly monitoring program. In the event that any adverse impacts to groundwater conditions occur, MPWMD shall halt operations and consult with the RWQCB to determine appropriate operational changes.


Mitigation Measure GWH-4: Operate Project in Compliance With NOAA Fisheries Recommendations and to Reduce Unlawful Diversions

MPWMD shall operate the Proposed Project in accordance with all of the bypass terms recommended by NOAA Fisheries in its 2002 report, Instream Flow Needs for Steelhead in the Carmel River, Bypass Flow Recommendations for Water Supply Projects Using Carmel River Waters. In addition, Cal-Am shall, to the maximum extent feasible, be required to utilize water that is available from the Seaside Basin due to the Proposed Project during the low-flow season from June 1 through November 30 to help reduce unlawful diversions from the Carmel River.


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Noise Mitigation Measure NZ-1a: Prohibit Ancillary and Unnecessary Equipment During Nighttime Well Drilling Activities. The project applicant shall ensure that the construction contractor prohibit the use of all ancillary and unnecessary equipment during nighttime hours. The only equipment that will be allowed to operate during nighttime activities would be the drilling and well construction equipment; cleanup and other activities will occur only during daytime activities.


Mitigation Measure NZ-1b: Employ Noise-Reducing Construction Practices to Meet Nighttime Standards. The construction contractor will employ noise-reducing construction practices such that nighttime standards (Table 10-3) are not exceeded. Measures that will be used to limit noise include, but are not limited to:

using noise-reducing enclosures around noise-generating equipment;

constructing barriers between noise sources and noise-sensitive land uses or taking advantage of existing barrier features (terrain, structures) to block sound transmission; and

enclosing equipment.


Mitigation Measure NZ-1c: Prepare a Noise Control Plan. The construction contractor will prepare a detailed noise control plan based on the construction methods proposed. This plan will identify specific measurement that will be taken to ensure compliance with the noise limits specified above. The noise control plan will be reviewed and approved by City of Seaside staff before any noise-generating construction activity begins.


Mitigation Measure NZ-1d: Disseminate Essential Information to Residences and Implement a Complaint/Response Tracking Program. The construction contractor will notify residences within 500 feet of the construction areas of the construction schedule in writing prior to construction.


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The construction contractor will designate a noise disturbance coordinator who will be responsible for responding to complaints regarding construction noise. The coordinator will determine the cause of the complaint and will ensure that reasonable measures are implemented to correct the problem. A contact telephone number for the noise disturbance coordinator will be conspicuously posted on construction site fences and will be included in the written notification of the construction schedule sent to nearby residents.


Mitigation Measure NZ-2: Design Pump Stations to Meet Local Noise Standards. MPWMD will design the new pump station and chemical/electrical building so that noise levels do not exceed applicable City of Seaside noise standards and ordinances. Prior to field acceptance, MPWMD will retain an acoustical consultant to measure noise levels from the operating facility. If project-generated noise exceeds the noise ordinance performance standards, additional noise attenuation measures will be implemented to meet the standards. The proposed facility will not receive final acceptance until the required noise standards are met. This measure will be made a condition of the final design review.


Hazards and Hazardous Materials Mitigation Measure HAZ-1: Implement MEC Safety Precautions during Grading and Construction Activities at the Project Site. Because of the proposed well site’s location, the following safety precautions are required for on-site activities. The requirements may be modified upon completion of the Munitions Response Remedial Investigation/Feasibility Study (MR RI/FS) process for the munitions response sites.

All personnel accessing the proposed well site will be trained in MEC recognition. This safety training is provided by the U.S. Army at no cost to the trainee. Training may be scheduled by contacting Fort Ord BRAC Office, Lyle Shurtleff at 831-242-7919.

If an item is discovered that is or could be MEC, it shall not be disturbed. The item shall be reported immediately to the Presidio of Monterey Police Department at 831-242-7851 so that appropriate U.S. military explosive ordnance disposal personnel can be dispatched to address such MEC as required under applicable law and regulations at the expense of the army.


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Ground disturbing activities, including perimeter fence installation, will be coordinated with USACE Unexploded Ordnance Safety Specialist so that appropriate construction-related precautions may be provided (Fisbeck pers. comm.). The USACE Pamphlet EP 75-1-2 entitled Munitions and Explosives of Concern (MEC) Support During Hazardous, Toxic and Radioactive Waste (HTRW) and Construction Activities, dated August 1, 2004, which can be found at http://www.usace.army.mil/inet/usace-docs/eng-pamphlets/ep75-1-2/toc.htm shall be followed by the USACE Safety Specialist to determine the type of construction oversight that will be needed based on the type of construction activities to be performed.

Construction activities at the project site are subject to Monterey County Code, Ordinance 5012, Subsection 1 dated 2005, Title 16 “Environment,” Chapter 16.1 “Digging and Excavating on the Former Fort Ord,” which can be found at http://municipalcodes.lexisnexis.com/codes/montereyco. This ordinance prohibits excavation, digging, development, or ground disturbance unless an excavation permit is obtained and the permit requirements are followed.


Public Services and Utilities Mitigation Measure PS-1: Coordinate Relocation and Interruptions of Service with Utility Providers during Construction The construction contractor will contact Underground Service Alert (800/642-2444) at least 48 hours before excavation work begins in order to verify the nature and location of underground utilities. In addition, the contractor will notify and coordinate with public and private utility providers at least 48 hours before the commencement of work adjacent to any utility, unless the excavation permit specifies otherwise. In addition, the service provider will be notified in advance of all service interruptions and will be given sufficient time to notify customers. The timing of interruptions will be coordinated with the providers to ensure that the frequency and duration of interruptions are minimized.


Mitigation Measure PS-2: Protect All Existing Utilities Slated to Remain The construction contractor will be responsible for ensuring protection of all utilities slated to remain. All buried lines will be tape-coated in accordance with the requirements of American Water Works Association C214. All new water services, fire services, and water mains will be cathodically protected, in accordance with contract documents. In addition, the contractor will be required to comply with State Department of Health Services criteria for the separation of water mains and sanitary sewers, as set forth in Section 64630, Title 22, of the


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California Administrative Code. MPWMD will ensure this measure is included in the contract specifications.


Visual Resources Mitigation Measure VIS-1: Incorporate Light-Reduction Measures into the Plan and Design of Exterior Lighting at Well Site. Where lighting is required or proposed, MPWMD will incorporate the following light-reduction measures into the lighting design specifications to reduce light and glare. The lighting design will also meet minimum safety and security standards.

Luminaires will be the minimum required for property security to minimize incidental light.

Luminaires will be cutoff-type fixtures that cast low-angle illumination to minimize incidental spillover of light onto adjacent properties and open space. Fixtures that project light upward or horizontally will not be used.

Luminaires will be focused only where needed (such as building entrances) and should not provide a general “wash” of light on building surfaces.

Luminaires will be directed away from habitat and open space areas adjacent to the project site.

Luminaires will provide good color rendering and natural light qualities. Low-pressure sodium and high-pressure sodium fixtures that are not color-corrected will not be used.

Luminaire mountings will be downcast and the height of poles minimized to reduce potential for backscatter into the nighttime sky and incidental spillover of light onto adjacent properties and open space. Light poles will be no higher than 20 feet. Luminaire mountings will have nonglare finishes.


Cumulative Impacts Mitigation Measure Cume-1: Coordinate with Relevant Local Agencies to Develop and Implement a Phased Construction Plan to Reduce Cumulative Traffic, Air Quality, and Noise Impacts MPWMD will contact local agencies that have projects planned in the same area (i.e., project sites within 1 mile or projects that affect the same roadways) and that have construction schedules that overlap with construction of the Proposed


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Project. MPWMD (or their contractor) will coordinate with local agencies responsible for said projects to develop a phased construction plan that includes the following components.

Evaluate roadways affected by construction activities and minimize roadway and traffic disturbance (e.g., lane closures and detours) and the number of construction vehicles using the roadways. This may involve scheduling some construction activities simultaneously or phasing.

Prepare compatible traffic control plans for construction projects. If one traffic control plan cannot be prepared, the construction contractor for the Proposed Project and the relevant local agencies (or their construction contractors) will ensure that the traffic control plans for projects affecting the same roadways are compatible. The traffic control plan can be modeled after that required for the Proposed Project in Chapter 2.

Phase construction activities so NOx and PM10 emissions remain below MPUAPCD thresholds. For medium and large projects (defined as projects that involve construction on a 1-acre site or larger because there is a reasonable likelihood it could contribute to exceeding the MBUAPCD NOx and PM10 emissions thresholds) that will be constructed during the same timeframe, MPWMD and the agencies will develop a phased construction plan so the cumulative NOx emissions remain below 137 pounds per day and the cumulative PM10 emissions remain below 82 pounds per day (or less than 2.2 acres per day is disturbed). The phased construction plan will identify planned construction activities and equipment, anticipated emissions, and a schedule that can be used to estimate daily emissions. The phased construction plan will be reviewed and approved by the MPUAPCD. It will likely be necessary for proponents of other projects to implement NOx-reducing construction practices, as well as dust reduction measures, to ensure NOx and PM10 emissions are at acceptable levels. The dust reduction measures should include all feasible measures contained in Table 8-2 of MBUAPCD’s CEQA Air Quality Guidelines (Getchell pers. comm.), which include the following.

Limit grading to 8.1 acres per day and grading and excavation to 2.2 acres per day.

Water graded / excavated areas at least twice daily. Frequency should be based on the type of operations, soil and wind exposure.

Prohibit all grading activities during periods of high wind (over 15 mph).

Apply chemical soil stabilizers on inactive construction areas (disturbed lands within construction projects that are unused for at least four consecutive days).

Apply nontoxic binders (e.g., latex acrylic copolymer) to exposed areas after cut and fill operations, and hydro-seed area.

Haul trucks shall maintain at least 2’0” of freeboard.

Cover all trucks hauling dirt, sand, or loose materials.


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Plant tree windbreaks on the windward perimeter of construction projects if adjacent to open land.

Plant vegetative ground cover in disturbed areas as soon as possible.

Cover inactive storage piles.

Install wheel washers at the entrance to construction sites for all exiting trucks.

Pave all roads at construction sites.


Temporary Pipeline Analysis Mitigation Measure WLD-1. Comply with U.S. Fish and Wildlife Service Biological Opinion Terms and Conditions. The U.S. Army will require that any contracts let to construct the proposed temporary pipeline include the U.S. Fish and Wildlife Service BO terms and conditions for Reasonable and Prudent Measures numbers 5, 6, and 7 (U.S. Fish and Wildlife Service 2005, pages 63–65).

Monitoring: Prior to initiation of construction activities, Cal-Am will ensure that this mitigation measure is implemented. Cal-Am is responsible for ensuring compliance for the duration of the project.

Mitigation Measure WLD-2: Remove Trees and Shrubs during the Nonbreeding Season for Most Birds (September 1 To February 15)

The placement and removal of the temporary pipeline may result in the trimming of trees and shrubs that provide suitable nesting habitat for migratory birds. To avoid the loss of active migratory bird nests, tree and shrub removal, if necessary, will be conducted only during the nonbreeding season for migratory birds (generally September 1 to February 15). Removing woody vegetation during the nonbreeding season will ensure that active nests will not be destroyed by removal of trees supporting or adjacent to active nests.

If shrub and tree trimming cannot be accomplished before the breeding season, a qualified wildlife biologist will conduct focused nest surveys for active nests of migratory bird species. If active nests are found in the project area, and if construction activities must occur during the nesting period, an appropriate “no-disturbance” buffer around the nest sites will be implement until the young have fledged (as determined by a qualified biologist).

Monitoring: Prior to initiation of construction activities, Cal-Am will ensure that this mitigation measure is implemented. Cal-Am is responsible for ensuring compliance for the duration of the project.


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Mitigation Measure CUL-1: Stop Work if Buried Cultural Deposits Are Encountered during Construction Activities

If buried cultural resources such as chipped or ground stone, quantities of bone or shell material, or historic debris or building foundations are inadvertently discovered during ground-disturbing activities, work will be stopped within a 100-foot radius of the find until a qualified archaeologist can assess the significance of the find. If, after evaluation by a qualified archaeologist, an archaeological site or other find is identified as meeting the criteria for inclusion in the NRHP or the CRHR, Cal-Am will retain a qualified archaeologist to develop and implement an adequate program for investigation, avoidance if feasible, and data recovery for the site, with Native American consultation, if appropriate.

If human skeletal remains are inadvertently encountered during construction of the temporary pipeline, the contractor will contact the Monterey County Coroner immediately. If the county coroner determines that the remains are Native American, the coroner will contact the NAHC, as required by Section 7050.5[c] of the California Health and Safety Code, and the County Coordinator of Indian Affairs. A qualified archaeologist will also be contacted immediately.

Monitoring: Cal-Am is responsible for ensuring that this mitigation measure is implemented. Cal-Am will conduct on-site monitoring during construction.

Mitigation Measure HAZ-1: Provide MEC Training to Construction Workers.

All construction workers that will enter the project site will receive training from qualified personnel on the identification and avoidance of MEC prior to beginning work.

Monitoring: Cal-Am is responsible for ensuring that this mitigation measure is implemented. Cal-Am will conduct on-site monitoring during construction.


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Chapter 5 References Cited

Printed References Binford, L. R. 1980. Willow Smoke and Dogs Tails: Hunter Gatherer

Settlement Systems and Archaeological Site Formation. American Antiquity 45 (1): 4–20. Available: <http://www.calforniaprehistory.com/reports01/ rep0023.html>.

Breschini, G.S., and Haversat, T. 1980. Preliminary Archaeological Report and Archaeological Management Recommendations for CA-Mnt-170, on Pescadero Point, Monterey County, California. MS. on file at the Northwest Information Center, Sonoma State University, Rohnert Park, California.

———. 1993. Report on Archaeological Investigations for Portions of CA-Mnt-1612, Pacific Grove, Monterey County, California. Available: <http://www.californiaprehistory.com/reports>.

Burt, W.H., and R.P Grossenheider. 1980. A Field Guide to the Mammals. 3rd edition. Boston, MA: Houghton Mifflin Company.

California Air Resources Board. 1998. Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant, Appendix III, Part A: Exposure Assessment, April. Sacramento, CA.

———. 2003. Proposed Amendments to the Area Designation Criteria and area Designations for State Ambient Air Quality Standards and Maps of Area Designations for State and National Ambient Air Quality Standards. December. Sacramento, CA

California Division of Mines and Geology. 1997. Guidelines for evaluation and mitigating seismic hazards in California. (Special Publication 117.) Last revised: May 28, 2002. Available: <gmw.consrv.ca.gov/shmp/ SHMPsp117.asp>. Accessed: June 26, 2003.

———. 2000. Digital Database of Faults from the Fault Activity Map of California and Adjacent Areas. (DMG CD 2000-006).


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Monterey Peninsula Water Management District References Cited

California Governor’s Office of Planning and Research. 2003. Guidelines for the Preparation and content of the Noise Element of the General Plan. Appendix A in State of California General Plan Guidelines. Sacramento, CA.

California Native Plant Society (CNPS). 2001. Inventory of Rare and Endangered Plants of California. (6th edition). Rare Plant Scientific Advisory Committee, David P. Tibor, Convening Editor. Sacramento, CA: Native Plant Society.

California Natural Diversity Database. 1999. List of California Terrestrial Natural Communities Recognized by the Natural Diversity Data Base. January. Sacramento, CA: Natural Heritage Division, Department of Fish and Game.

———. 2005a. Rare Find 3, Version 3.0.5 (April 29, 2005). Records search of the Marina, Seaside, Monterey, Spreckels, and Salinas 7.5-minute quadrangles. Sacramento, CA: California Department of Fish and Game.

———. 2005b. Rare Find 3, Version 3.0.5 (April 29, 2005). Records search for Monterey dusky-footed woodrat (Neotoma fuscipes luciana). Sacramento, CA: California Department of Fish and Game.

———. 2005c. Rare Find 3, Version 3.0.5 (April 29, 2005). Records search for American badger (Taxidea taxus) in Monterey County. Sacramento, CA: California Department of Fish and Game.

California State Parks, et al. 2006. Carmel River Barrier Beach and Lagoon. Development of a Long Term Adaptive Management Plan, Criteria For Maintaining Listed Threatened And Endangered Species Habitat Values. Developed by a consortium of agencies including California Dept of Parks and Recreation, National Marine Fisheries Service, Monterey County Public Works, Monterey County Water Resources Agency, Monterey Peninsula Water Management District, U.S. Fish and Wildlife Service, and U.S. Army Corp of Engineers.

Camp, Dresser & McKee. 2003. Monterey Peninsula Water Supply Project Alternatives; Final Phase 1 Technical Memorandum. March. Prepared for the Monterey Peninsula Water Management District. Walnut Creek, CA.

City of Seaside. 2003a. City website. Available: <www.ci.seaside.ca.us>. Accessed July 29, 2003.

———. 2003b. City of Seaside Draft General Plan. Seaside, CA.

———. 2005. Seaside General Plan. August. Seaside, CA.

Clark, J., W. Dupré, and L. Rosenberg. 1997. Geologic map of the Monterey and Seaside 7.5-minute quadrangles, Monterey County, California: A digital database. U.S. Geological Survey Open File Report 97-30.Cook, T. 1978.


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Soil survey of Monterey County, California. Washington DC: U.S. Department of Agriculture, Soil Conservation Service.

Dettman, D.H. 1986. Relationships between steelhead sport catch, angling success, and streamflows in the Carmel River during 1984, Appendix F in D.W. Kelley, Assessment of the Carmel River Steelhead Resource, Vol I. Prepared for the Monterey Peninsula Water Management District. Monterey, CA.

———. 1989. Evaluation of Instream Flow Recommendations for Adult Steelhead Upstream Migration in the Lower Carmel River. October. (Monterey Peninsula Water Management District Technical Memorandum 89-05). Monterey, CA.

———. 1994. Recommended Flows for Incubation of Steelhead Eggs below San Clemente Dam – Spring 1994. (MPWMD Technical Memorandum No. 94-02). March.

Dettman, D. H., and D. W. Kelley. 1986. Assessment of the Carmel River Steelhead Resource. Vol. I. Biological Investigations. Prepared for the Monterey Peninsula Water Management District. Monterey, CA.

Dupré, William, R. 1990. Quaternary Geology of the Monterey Bay Region, California, in Geology and Tectonics of the Central Coast Region, San Francisco to Monterey, Volume and Guidebook. Association of Petroleum Geologists, Pacific Section. June.

Ecosystems West Consulting Group. 2001. Biological Assessment of California Red-legged Frog for the Carmel River Dam and Reservoir Project, Monterey County, California. December. Interim Draft. Prepared for Monterey Peninsula Water Management District, U.S. Army Corps of Engineers, and California-American Water Company. Santa Cruz, CA.

Entrix. 2000. Final Draft Biological Assessment for the Seismic Retrofit of San Clemente Dam. Prepared for U.S. Army Corps of Engineers. January 7.

Environmental Simulations, Inc., (2003), Guide to Using AquiferWin32/WinFlow–WinTran Version 3.

Federal Transit Administration. 1995. Transit Noise and Vibration Impact Assessment. Washington, DC.

Fields, W.C. 1984. The invertebrate fauna of the Carmel River system and food habits of fish in the Carmel River system. Appendix C to Assessment of Carmel River Steelhead Resource: Its Relationship to Streamflow and to Water Supply Alternatives. Vol. I., D. W. Alley & Associates. Prepared for the Monterey Peninsula Water Management District. Monterey, CA.

Fink, Augusta. 1972. Monterey County. The Dramatic Story of its Past. Santa Cruz, CA: Western Tanager Press.


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Fisheries Working Group. 1994. Completion Report: Recommended Instream Flow Requirements for the Carmel River Steelhead Resource. Prepared by Monterey Peninsula Water Management District, California Dept of Fish and Game, and National Marine Fisheries Service. March.

Fort Ord Reuse Authority. 1997. Fort Ord Reuse Plan. Prepared with technical assistance from EMC Planning Group, Inc. and EDAW, Inc. June. Marina, CA.

Froke, J. B. 2005. Biological Assessment for a Temporary Emergency Intertie of the California American Water System to the Santa Margarita Test Injection Well - California Tiger Salamander - Former Fort Ord, Monterey County, California. March. Prepared for U.S. Army Presidio of Monterey. Seaside, CA.

Fugro West, Inc. 1997. Hydrogeologic Assessment, Seaside Coastal Groundwater Subareas, Phase III Update.

Griffin, J.R. 1976. Native plant reserves at Fort Ord. Fremontia 4(2):25–28.

Hart, E. W., and W. A. Bryant. 1997. Fault-rupture Hazard Zones in California: Alquist-Priolo Earthquake Fault Zoning Act with Index to Earthquake Fault Zone Maps. California Division of Mines and Geology Special Publication 42. Sacramento, CA.

Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. Sacramento, CA: State of California, the Resources Agency, Department of Fish and Game.

James, G. W. 2005. Surface Water Dynamics at the Carmel River Lagoon, Water Years 1991 through 2005. (Technical Memorandum 05-01). Monterey Peninsula Water Management District. 44 pp +Appendices.

Jennings, C. 1994. Fault activity map of California and adjacent areas with locations and ages of recent volcanic eruptions. California Geologic Data Map Series, Map No. 6. Sacramento, CA: California Department of Conservation, Division of Mines and Geology.

Jennings, M. R., and M. P. Hayes. 1994. Amphibian and Reptile Species of Special Concern in California. Final report. Rancho Cordova, CA: California Department of Fish and Game, Inland Fisheries Division.

Kelley et al. 1987. Preservation of the Carmel River Steelhead Run with Fish Passage Facilities over New San Clemente Dam or with a Hatchery near Its Base. Prepared for the Monterey Peninsula Water Management District. 26 pp. + Appendices.

Kyle, D. E. 1990. Historic Spots in California. Stanford, CA: Stanford University Press.


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Levy, R. 1978. Eastern Miwok. In California, edited by R. F. Heizer, pp. 398–413. Handbook of North American Indians, vol. 8, W. C. Sturtevant, general editor. Smithsonian Institution: Washington, DC.

Mayer, K. E., and W. F. Laudenslayer, Jr. 1988. A Guide to Wildlife Habitats of California. October. Sacramento, CA: California Department of Forestry and Fire Protection.

McEwan D., and T. A. Jackson. 1986. Steelhead Restoration and Management Plan for California. February. State of California, the Resources Agency, California Department of Fish and Game. 234 pp.

McNeish, C. M. 1989. An Inventory of the Riparian Vegetation Resource of the Carmel Valley. Prepared for Monterey Peninsula Water Management District, Monterey CA.

Milliken, R. 1992. Ethnographic and Ethnohistoric Background for the San Francisquito Flat Vicinity, Carmel Valley, Monterey County, California. Appendix 2 in Baseline Archaeological Studies at Rancho San Carlos, Carmel Valley, Monterey County, California by Gary S. Breschini and Trudy Haversat. Submitted to Rancho San Carlos Partnership.

Monterey Bay Unified Air Pollution Control District. 2004. CEQA Air Quality Guidelines. Monterey, CA.

Monterey County. 2001. Draft, 21st Century, Monterey County General Plan. December. Available: <http://www.co.monterey.ca.us/gpu/Reports /Draft%20General%20Plan.htm>. Accessed: July 1, 2003.

Monterey Peninsula Water Management District. 1994. Monterey Peninsula Water Supply Project Final Environmental Impact Report and Statement. Volume I – Summary and Chapters 1-24. (State Clearinghouse No. 03033025). March. Prepared by EIP Associates. San Francisco, CA.

Monterey Peninsula Water Management District. 1996. Evaluation of MPWMD Five-Year Mitigation Program 1991–1996. Final. A component of the MPWMD Water Allocation EIR. October. Monterey, CA.

———. 2004. Environmental and Biological Assessment of Portions of the Carmel River Watershed, Monterey County, California. Prepared for Carmel River Watershed Conservancy as part of the Carmel River Watershed Assessment and Action Plan. Monterey, CA.

NOAA Fisheries (National Oceanic and Atmospheric Administration National Marine Fisheries Service). 2002. Instream Flow Needs for Steelhead in the Carmel River. Bypass Flow Recommendations for Water Supply Projects using Carmel River Waters. June. Santa Rosa, CA.

Pacific Municipal Consultants. 2004. Archaeological Investigations for the General Jim Moore Boulevard and Eucalyptus Road Improvement Project on


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the Former Fort Ord, Monterey County, CA. Report prepared for the Fort Ord Reuse Authority. Monterey, CA.

Padre Associates, Inc. 2003. Summary of Operations, Water Year 2002 Injection Testing, Santa Margarita Test Injection Well. Prepared for Monterey Peninsula Water Management District. Ventura, CA.

———. 2004. Summary of Operations: Water Year 2003 Injection Testing, Santa Margarita Test Injection Well. Prepared for Monterey Peninsula Water Management District. Ventura, CA.

———. 2005. Summary of Operations: Water Year 2004 Injection Testing, Santa Margarita Test Injection Well. Prepared for Monterey Peninsula Water Management District. Ventura, CA.

Peak, Ann S., and Associates. 1978. Cultural Resources Assessment of the Monterey Regional Wastewater Treatment System, Monterey, California. On file at the Northwest Information Center, Sonoma State University. Rohnert Park, CA.

Petersen, M., D. Beeby, W. Bryant, C. Cao, C. Cramere, J. Davis, M. Reichle, G. Saucedo, S. Tan, G. Taylor, T. Toppozada, J. Treiman, and C. Wills. 1999. Seismic shaking hazard maps of California. Sacramento, CA: California Division of Mines and Geology.

RBF Consulting and Denise Duffy & Associates. 2003. Marina Coast Water District Regional Urban Water Augmentation Project Engineering Feasibility Study. August. Monterey, CA.

Raines, Melton & Carella, Inc. 2002. Plan B Project Report, A.97-03-052. July. Prepared in association with EDAW, Inc. for the Water Division of the California Public Utilities Commission. Walnut Creek, CA.

Randall, Judge Roger D. 2006. Tentative decision, Monterey County Superior Court Case No. M66343, California American Water vs. City of Seaside et al.; issued January 12, 2006.

Remsen, J. V. 1978. Bird Species of Special Concern in California: An Annotated List of Declining or Vulnerable Bird Species. (Nongame Wildlife Investigations, Wildlife Management Branch alluvial report No. 78–1.) California Department of Fish and Game. Sacramento, CA.

Reveal, J.L., and C. B. Hardham. 1989. A revision of the annual species of Chorizanthe (Polygonaceae eriogonoidea). Phytologia. 66(2):98–198.

Rosenberg, L.I. 2001. Geologic Resources and Constraints, Monterey County, California: A technical report for the Monterey County 21st Century General Plan Update Program. Prepared for Monterey County Environmental Resource Policy Department. Salinas, CA.


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Sawyer, J. O., and T. Keeler-Wolf. 1995. A Manual of California Vegetation. Sacramento, CA: California Native Plant Society.

Snider, W. M. 1983. Reconnaissance of the Steelhead Resource of the Carmel River Drainage, Monterey County. (Administrative Report 83-3.) Sacramento, CA: California Department of Fish and Game, Environmental Services Branch.

Southern California Earthquake Data Center. 2003. Southern California Earthquake Data Center, Rinconada fault. March. Available: <http://www.scecdc.scec.org/index.html>. Accessed: July 3, 2003.

Staal, Gardner and Dunne, Inc. 1987. Hydrogeologic Investigation, Seaside Coastal Ground Water Basin. Ventura, CA.

———. 1990. Hydrogeologic Update, Seaside Coastal Ground Water Basins. Ventura, CA.

Stebbins, R. C. 1985. A Field Guide to Western Reptiles and Amphibians. 2nd edition. Boston, MA: Houghton Mifflin Company.

———. 2003. A Field Guide to Western Reptiles and Amphibians. 3rd edition. Boston, MA: Houghton Mifflin Company.

Storer, T. 1925. A synopsis of the amphibian of California. University of California Publications in Zoology 27:1–342

Swernoff, M. 1982. A Reconnaissance Cultural Resources Survey of Fort Ord, California. Professional Analysts. Prepared for U.S. Department of the Army, Sacramento Corps of Engineers. Sacramento, CA.

Theis, C.V. 1935. Relationship Between Lowering of Piezometer Surface on the Fate and Duration of Discharge of a Well Using Ground Water Storage. Transactions of the Geophysical Union 16:519–524.

U.S. Army Corps of Engineers, Sacramento District. 1992a. Flora and Fauna Baseline Study of Fort Ord, California. December. With technical assistance from Jones & Stokes Associates, Inc. (JSA 90-214.) Sacramento, CA.

———. 1992b. Fort Ord Disposal and Reuse Environmental Impact Statement, Volume I: Draft. December. With technical assistance from Jones & Stokes Associates, Inc. Sacramento, CA.


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———. 1996. Final Supplemental Environmental Impact Statement for Fort Ord Disposal and Reuse. June. With technical assistance from Jones & Stokes Associates, Inc. Sacramento, CA.

———. 1997. Installation-wide Multispecies Habitat Management Plan for Former Fort Ord, California. April. With technical assistance from Jones & Stokes Associates, Inc. Sacramento, CA.

U.S. Department of Agriculture, Soil Conservation Service. 1979. Soil Survey of Monterey County, CA. April.

U.S. Fish and Wildlife Service. 1999. Biological and Conference Opinion on the Closure and Reuse of Fort Ord, Monterey County, California. (1-8-99-F/C-39R). March 30, 1999. Ventura, CA.

———. 2002a. Biological Opinion on the Closure and Reuse of Fort Ord, Monterey County, California, as it Affects Monterey Spineflower Critical Habitat. (1-8-01-F-70R). October 22, 2002. Ventura, CA.

———. 2002b. Recovery Plan for the California Red-legged Frog (Rana aurora draytonii). Portland, OR. viii + 173 pp.

———. 2005. Cleanup and Reuse of Former Fort Ord, Monterey County, California, as it Affects California Tiger Salamander and Critical Habitat for Contra Costa Goldfields. (1-8-04-F-25R). Ventura, CA. 14 March, 2005. Pp. 44 and 52.

Weber T. and A. Peak. 1976. Site Record for CA-Mnt-699. On file at the Northwest Information Center, Sonoma State University. Rohnert Park, CA.

Williams, D. F. 1986. Mammalian Species of Special Concern in California. (Wildlife Management Division Administrative Report 86-1.) Sacramento, CA: California Department of Fish and Game.

WRIME, Inc. 2003. Deep Aquifer Investigative Study. May. Prepared for Marina Coast Water District, Marina California. Sacramento, CA.

Yates, E., et al. 2005. Seaside Groundwater Basin: Update on Water Resource Conditions. Prepared for Monterey Peninsula Water Management District. Berkeley, CA.

Zeiner, D. C., F. Laudenslayer, K. E. Mayer, and M. White. 1988. Amphibians and Reptiles. Volume I of California Wildlife. Sacramento, CA: California Department of Fish and Game.

———. 1990a. Birds. Volume II of California Wildlife. Sacramento, CA: California Department of Fish and Game.

———. 1990b. Mammals. Volume III of California Wildlife. Sacramento, CA: California Department of Fish and Game.


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Personal Communications Brennan, Janet. Supervising air quality planner. Monterey Bay Unified Air

Pollution Control District, Monterey, CA. April 4, 2003—telephone conversation.

Christensen, Thomas. Riparian projects coordinator. Monterey Peninsula Water Management District, Monterey, CA. November and December 2002— telephone conversations and email messages with Gerrit Platenkamp, Jones & Stokes.

Collins, William. Wildlife biologist. U.S. Army Base Realignment and Closure Office at Fort Ord, Seaside, CA. December 15, 2005—e-mail.

Craft, David. Air pollution control engineer. Monterey Bay Unified Air Pollution Control District, Monterey, CA. August 4, 2005—telephone conversation.

Fisbeck, Karen. Director, Base Realignment and Closure Office. U.S. Army at Fort Ord, CA. November 30, 2005—email.

Getchell, Jean. Supervising air quality planner. Monterey Bay Unified Air Pollution Control District, Monterey, CA. December 15, 2005—email to Shannon Hatcher, Jones & Stokes; July 21, 2006—telephone conversation with Shannon Hatcher, Jones & Stokes; July 24, 2006—email to Shannon Hatcher, Jones & Stokes.

Jaques, Robert. Monterey Regional Water Pollution Control Agency. Feb. 1, 2005—e-mail to Henrietta Stern, Monterey Peninsula Water Management District.

Lucca, Marc. Deputy general manager. Marina Coast Water District, Marina, CA. December 13, 2005—telephone conversation.


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Chapter 6 Report Preparation

The following individuals were involved in the preparation of this EIR.

Monterey Peninsula Water Management District Henrietta Stern Project Management

David Dettman Aquatic Resources

Darby Fuerst Aquatic Resources and Hydrology

Joe Oliver Seaside Groundwater Basin Water Quality and Hydrology

Jones & Stokes Mike Rushton Project Management; Project

Description; Aquatic Resources; Geology, Seismicity, and Soils; Hydrology and Water Quality; Cumulative Effects

Jennifer Alvarez Wildlife

Jennifer Ames Land Use, Hazards and Hazardous Materials, Public Services and Utilities, Transportation and Circulation, Visual Resources

Shannon Hatcher Air Quality and Noise

Corrine Ortega Document Production

Robert Preston Vegetation

Gregg Roy Introduction and Alternatives


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Monterey Peninsula Water Management District Report Preparation

Barbara Siskin Cultural Resources

Bud Widdowson Wildlife

Margaret Widdowson Vegetation

Jessica Hankins Final EIR Management

Padre Associates, Inc. Steve Tanner Project Description

Robert Marks Hydrology and Water Quality


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